Jahangiri v. Arcadis, U.S., Inc.

Background

Jay Jahangiri and Azam Azimi sued their former employer, Arcadis U.S., Inc. Their amended complaint alleged discrimination, harassment, retaliation, and wrongful termination under Title VII of the Civil Rights Act of 1964 and California’s Fair Employment and Housing Act. The complaint also included class allegations.

Jahangiri alleged that supervisors and coworkers made remarks about his national origin, religion, and age, and that his employment was terminated. Azimi alleged discriminatory remarks and other adverse employment actions, including loss of remote-work authorization, denial of a company vehicle and travel allowance, demotion, a performance improvement plan, and termination.

Arcadis moved under Federal Rule of Civil Procedure 12 to dismiss, strike portions of the complaint, or transfer the case to the Eastern District of California. Arcadis separately moved under Rule 21 to sever Azimi’s claims.

Motion to dismiss, strike, or transfer

The court ruled that Arcadis’s motion to strike was timely because the 21-day period began when the amended complaint was manually served on June 6, 2025, rather than when it was electronically filed. Arcadis filed its motion 21 days later.

The court denied the request to dismiss for improper venue. Title VII permits venue in any judicial district in the state where the alleged unlawful employment practice occurred. Because the parties did not dispute that the alleged practices occurred in California, the Northern District of California was a proper venue.

The court also denied transfer under 28 U.S.C. § 1404(a). Although the Eastern District had more witnesses, personnel records, and connections to the claims, those factors favored transfer only slightly. The court found that Jahangiri’s choice of the Northern District deserved substantial deference under Title VII’s broader venue provision, and that Arcadis had not made the strong showing of inconvenience required to disturb that choice. The court also considered the neighboring districts’ relative convenience, modern electronic document production and videoconferencing, docket congestion, and the statewide nature of the proposed class.

The court declined to decide Arcadis’s argument that Jahangiri improperly combined discrimination and harassment claims because Arcadis provided no supporting legal analysis and did not appear to request dismissal or striking of those portions of the complaint.

The court construed Arcadis’s challenge to Jahangiri’s class allegations as a motion to strike under Rule 12(f). It held that the challenge was premature because Arcadis had not answered, discovery had not begun, and no motion for class certification had been filed. The court therefore denied the motion to dismiss the class claims without prejudice.

Severance of Azimi’s claims

Rule 20 permits multiple plaintiffs to proceed together when their claims arise from the same transaction or occurrence and share a question of law or fact. The court concluded that the plaintiffs had not met the same-transaction requirement. Their claims involved different jobs, employment periods, direct supervisors, additional alleged offenders, remarks made at different times, and different alleged adverse actions. Only two incidents overlapped. The court also found that resolving the claims would require individualized analysis of the plaintiffs’ performance and the employer’s stated reasons for its actions.

Because the claims required individualized litigation, the court granted Arcadis’s motion to sever. The court found that the plaintiffs had not identified any substantial right that would be prejudiced by severance. It therefore exercised its Rule 21 authority to sever and dismiss Azimi’s claims without prejudice. The court did not decide Arcadis’s argument that Azimi’s claims were untimely.

Disposition

The court denied Arcadis’s motion to dismiss, strike, and transfer; granted Arcadis’s motion to sever; and dismissed Azimi from the action without prejudice. The action proceeded with Jahangiri only.