C.H. Robinson Worldwide, Inc. v. Traffic Tech, Inc.

Background

C.H. Robinson Worldwide, Inc. sued Traffic Tech, Inc. and six individuals. The complaint alleged that the individual defendants entered employment-related contracts, including non-solicitation, arbitration, and bonus agreements, and breached those agreements after accepting employment with Traffic Tech. The complaint asserted six counts: breach of contract; tortious interference with contract; tortious interference with prospective economic advantage; breach of confidentiality duty; inducing, aiding, and abetting breaches; and conspiracy.

C.H. Robinson originally filed the case in Minnesota state court. The defendants removed it based on diversity jurisdiction. The defendants later filed a partial motion to dismiss. They argued that C.H. Robinson was not the proper party to bring claims against Iman Dadkhah and Miles Maassen because those two individuals had been employees of C.H. Robinson’s subsidiary, Freightquote.com, Inc., rather than C.H. Robinson. They also argued that Counts IV, V, and VI failed to state claims.

Report and Recommendation

Magistrate Judge David Schultz recommended allowing C.H. Robinson 30 days to join Freightquote.com as a plaintiff rather than immediately dismissing the claims involving Dadkhah and Maassen. If C.H. Robinson did not join Freightquote.com, the recommendation stated that Dadkhah and Maassen should be dismissed because C.H. Robinson lacked standing to sue them. The recommendation noted that joining Freightquote.com would destroy diversity jurisdiction.

The magistrate judge also recommended granting the motion to dismiss Counts IV, V, and VI because the 57-page complaint, together with 34 exhibits totaling 130 pages, did not provide the “short and plain statement” required by Federal Rule of Civil Procedure 8. The recommendation allowed C.H. Robinson to file an amended complaint pleading those counts with greater clarity and brevity. C.H. Robinson filed no objections to the recommendation.

Motion for Voluntary Dismissal

Instead of following the recommended procedure, C.H. Robinson moved under Federal Rule of Civil Procedure 41(a)(2) to dismiss the action without prejudice. It stated that it intended to add Freightquote.com as a plaintiff and that doing so would destroy complete diversity. The defendants opposed dismissal, arguing that C.H. Robinson should first seek to join Freightquote.com and then seek a remand if federal jurisdiction no longer existed. They also argued that the requested dismissal would let C.H. Robinson avoid an unfavorable ruling and seek a more favorable forum.

The court considered whether C.H. Robinson had given a proper reason for dismissal, whether dismissal would waste judicial resources, and whether it would prejudice the defendants. The court emphasized that the case had been pending for more than a year, discovery had been exchanged and was continuing, and dispositive motions had been filed. It concluded that voluntary dismissal would allow C.H. Robinson to avoid the consequences of the ruling on the defendants’ dismissal motion and therefore denied the request.

Order

The court adopted Magistrate Judge Schultz’s Report and Recommendation in its entirety. It granted in part and denied in part the defendants’ partial motion to dismiss: the motion concerning Dadkhah and Maassen was granted, but C.H. Robinson received 30 days to join Freightquote.com; if it did not, Dadkhah and Maassen would be dismissed from the lawsuit. The motion to dismiss Counts IV, V, and VI was granted without prejudice, and C.H. Robinson received 30 days to file an amended complaint repleading those counts. The court also denied C.H. Robinson’s motion for voluntary dismissal.