Wilson v. Target Corporation

Background

Jasaray Wilson filed an unverified complaint in Alameda County Superior Court on November 20, 2024. Target removed the case to federal court on January 2, 2025, based on diversity jurisdiction. Wilson alleged that Target, described as her former employer, discriminated against her, harassed her, retaliated against her, and wrongfully terminated her based on her gender and sex.

Wilson asserted nine causes of action: discrimination under California’s Fair Employment and Housing Act (FEHA); failure to prevent discrimination; retaliation under FEHA; harassment under FEHA; failure to prevent harassment; retaliation under California Labor Code section 98.6; retaliation under section 1102.5; retaliation under section 6310; and wrongful termination in violation of public policy.

The court held an initial case-management conference on May 22, 2025, and set June 6, 2025, as the deadline to amend the pleadings. Wilson did not amend the complaint by that deadline. Target later moved for judgment on the pleadings under Federal Rule of Civil Procedure 12(c).

Court’s Analysis

A motion for judgment on the pleadings is functionally the same as a motion to dismiss for failure to state a claim. The court accepts the complaint’s material allegations as true but requires enough factual content to make a claim plausible rather than speculative.

The court held that Wilson’s FEHA discrimination claim failed because she made only a general statement that she experienced discrimination, harassment, and retaliation based on gender. The complaint did not identify Wilson’s gender, explain how gender affected any decision, or identify a specific discriminatory event or action.

The court also held that the FEHA harassment claim failed. Although the complaint referred to sexual harassment, sexual assault, unwanted touching, and unwanted advances, it did not identify the alleged harassers, provide details about the conduct, or explain why the conduct was sufficiently severe or widespread to create a legally actionable hostile work environment.

The retaliation claims under FEHA and Labor Code sections 98.6, 1102.5, and 6310 also failed. Wilson did not identify when or to whom she reported the alleged harassment, and the complaint did not provide facts showing protected activity or a connection between protected activity and an adverse employment action. It also did not allege facts showing that she complained about Labor Code violations or unsafe work conditions as required for the relevant claims.

The court held that the claims for failure to prevent discrimination, failure to prevent harassment, and wrongful termination in violation of public policy were derivative claims. Because the underlying discrimination and harassment claims failed, these related claims failed as well. The court also noted Target’s argument that the complaint did not allege that Wilson worked for Target or provide information about Target in the complaint’s parties section.

Amendment and Disposition

Wilson asked for permission to amend in her opposition brief. Because the court-ordered amendment deadline had passed, she first had to show good cause under Rule 16 of the Federal Rules of Civil Procedure. The court found that she had not shown the required diligence: she had not amended during the permitted period and did not identify facts or evidence showing that she could plausibly state any of the nine claims.

The court further concluded that the additional allegations in Wilson’s opposition—that she was forced to work in unsafe conditions and was physically assaulted by a Target employee—were too conclusory to support amendment. The court found that amendment would be futile.

The court GRANTED Target’s motion for judgment on the pleadings and DISMISSED the case with prejudice. The opinion does not separately state a ruling verb for each individual cause of action, but its analysis concludes that all nine causes of action failed.