Rodriguez v. Target Corporation
- Lorna Schofield
- 1:22-cv-02982
- U.S. District Court · Southern District of New York
- 2
In Rodriguez v. Target Corporation, Judge Schofield denied plaintiffs’ motion to reconsider claims about fish-oil labels.
The ruling directly affected plaintiffs Jose Rodriguez and Sherri Morris and defendants Target Corporation and Lang Pharma Nutrition Inc. It left the earlier treatment of plaintiffs’ fish-oil labeling claims unchanged.
What happened
Rodriguez v. Target Corporation is a class action brought by Jose Rodriguez and Sherri Morris against Target Corporation and Lang Pharma Nutrition Inc. Plaintiffs asked the court to reconsider an earlier decision on their claims about the defendants’ fish-oil product labels.
The earlier decision allowed some claims to continue, including claims that statements beyond the words “fish oil” could mislead reasonable consumers about whether the products contained what plaintiffs called “pure” or “natural” fish oil. The court did not find sufficient allegations that the labels were misleading about how or where the fish was caught, including the words “wild” and “Alaska.”
The court denied plaintiffs’ motion for reconsideration. Judge Lorna G. Schofield said plaintiffs had not identified overlooked allegations or legal authority that could reasonably be expected to change the earlier decision.
The detailed version
- Rodriguez v. Target Corporation · No. 1:22-cv-02982
- Lorna Schofield
- Jan. 18, 2023
Background
Jose Rodriguez and Sherri Morris, on behalf of themselves and others similarly situated, sued Target Corporation and Lang Pharma Nutrition Inc. The opinion concerns plaintiffs’ motion for reconsideration under Local Civil Rule 6.3 and Rule 59 of the Federal Rules of Civil Procedure. Plaintiffs sought reconsideration of the court’s earlier opinion and order on their Second Amended Complaint, which had granted defendants’ motion in part and dismissed the complaint in part.
Earlier Ruling
The court had determined that plaintiffs sufficiently alleged that the defendants’ labeling could mislead a reasonable consumer about whether the products contained what plaintiffs described as “pure” or “natural” fish oil. The court stated that plaintiffs could argue that label statements beyond the words “fish oil” contributed to that alleged deception.
The court also held that plaintiffs had not sufficiently alleged that the labels could mislead consumers about how or where the fish were caught, including the words “wild” and “Alaska.” The court distinguished cases involving labels that emphasized desirable ingredients making up only a small part of a product, such as “real fruit” or “whole grain.” According to the opinion, plaintiffs had not alleged that the products contained fish caught in a manner different from the manner described on the labels.
Motion for Reconsideration
A motion for reconsideration asks the court to revisit an earlier decision. The court explained that relief is available only when the moving party identifies an intervening change in controlling law, new evidence, or a need to correct a clear error or prevent serious unfairness. The standard is strict and generally requires a showing that the court overlooked controlling decisions or information that could reasonably change its conclusion.
Ruling
The court denied plaintiffs’ motion for reconsideration. It concluded that plaintiffs had not identified any allegations or legal authority that the court had overlooked when deciding defendants’ motion. The opinion does not state that the court changed any part of its earlier ruling.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.