Sanchez v. Roadrunner Transportation Services, Inc.
- Maxine Chesney
- 3:21-cv-00890
- U.S. District Court · Northern District of California
- 2
In Sanchez v. Roadrunner Transportation Services, Inc., Judge Chesney transferred the later-filed action to Wisconsin under the first-to-file rule, granting in part and denying in part defendants’ motion.
The plaintiffs’ action was moved from the Northern District of California to the United States District Court for the Eastern District of Wisconsin. The ruling affected Jose Francisco Sanchez, Jose Antonio Reyes, and the two Roadrunner defendants.
What happened
Jose Francisco Sanchez and Jose Antonio Reyes sued Roadrunner Transportation Services, Inc. and Roadrunner Transportation Systems, Inc. over claims similar to those in an earlier class action involving the same defendants. The cases differed in the class-period start date and because Sanchez included one additional claim.
Defendants asked the court to dismiss the case or transfer it based on a forum-selection clause and the first-to-file rule. The court found that the first-to-file rule applied and determined that transferring the case was preferable to dismissing it. It ordered the action transferred to the U.S. District Court for the Eastern District of Wisconsin, and stated that the motion was granted in part and denied in part.
Judge Maxine M. Chesney issued the July 27, 2021 order. The order did not specify which portions of defendants’ motion were granted or denied beyond ordering the transfer.
The detailed version
- Sanchez v. Roadrunner Transportation Services, Inc. · No. 3:21-cv-00890
- Maxine Chesney
- July 27, 2021
Background
The plaintiffs filed this action against Roadrunner Transportation Services, Inc. and Roadrunner Transportation Systems, Inc. The opinion states that the action asserted essentially the same claims as an earlier case filed on behalf of a named plaintiff and a proposed class under California Labor Code sections 2802 and 2804, California Labor Code sections 2698 and following, and California Business and Professions Code sections 17200 and following. The cases differed in the starting date of the proposed class period and because this action included the additional California Labor Code claim.
The earlier case had been filed in state court, removed to the Northern District of California, and later transferred to the Eastern District of Wisconsin after the court granted a motion based on a forum-selection clause.
Court’s analysis
Defendants moved to dismiss this action or, alternatively, to transfer it. The court applied the first-to-file rule, a rule that can allow a court to transfer, pause, or dismiss a later-filed case when an earlier case involves substantially the same parties and issues. The court found that this action was subject to dismissal or transfer under that rule and concluded that transfer was preferable.
The court also noted that the earlier case had not been dismissed. Although the plaintiffs said dismissal was likely, the docket showed that no dismissal had been filed and that an answer had been filed. The court stated that any dismissal would therefore require a stipulation or court order. It further stated that, if the earlier case were later dismissed in Wisconsin, the parties could present their positions to that court about whether this action should remain there.
Disposition
The court ordered the action transferred to the United States District Court for the Eastern District of Wisconsin. It stated that defendants’ motion was "GRANTED in part and DENIED in part." The opinion does not identify which specific portions of the motion corresponded to the grant and denial.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.