Craig v. American Tuna Inc.

CourtDistrict Court, S.D. New York
DecidedApril 1, 2022
Docket1:21-cv-09125
StatusUnknown

This text of Craig v. American Tuna Inc. (Craig v. American Tuna Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. New York primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Craig v. American Tuna Inc., (S.D.N.Y. 2022).

Opinion

USDC SDNY DOCUMENT UNITED STATES DISTRICT COURT ELECTRONICALLY FILED SOUTHERN DISTRICT OF NEW YORK DOC #: DATE FILED: 4/1/2022 JEFFREY CRAIG, Plaintiff, OPINION AND ORDER ON MOTION TO TRANSFER ~against- 21-CV-9125 (AJN)(KHP)

AMERICAN TUNA, INC. et al., Defendants.

KATHARINE H. PARKER, UNITED STATES MAGISTRATE JUDGE Defendant American Tuna, Inc. (“American Tuna”) has moved to transfer this action to the United States District Court for the Southern District of California pursuant to 28 U.S.C. § 1404(a) and Federal Rule of Civil Procedure (“FRCP”) 12(b)(3) and to dismiss certain claims under FRCP 12(b)(6).1 (ECF No. 25.) For the reasons set forth below, Defendant’s motion to transfer is granted. Because the case is transferring, the Court does not rule on the motion for partial dismissal but notes that Plaintiff agrees to withdraw his unjust enrichment claim and claim under the Magnuson-Moss Act 15 U.S.C. § 2301.

1 After American Tuna moved to transfer venue and dismiss claims (ECF No. 11), Plaintiff filed an amended complaint on January 31, 2022, adding Defendant World Wise Foods, Ltd. (hereinafter, “WWF”), American Tuna’s parent company, located in the United Kingdom, and more factual allegations to further support his claims. (ECF No. 21.) American Tuna then renewed its motion. (ECF No. 25.) WWE has not been served as of the date of this decision. However, it has submitted a declaration in connection with American Tuna’s motion stating that it objects to jurisdiction in New York and consents to jurisdiction in the Southern District of California. (ECF No. 28.)

BACKGROUND2 Plaintiff, Jeffrey Craig, a resident of New Jersey, purchased American Tuna’s canned tuna fish from Whole Foods locations in New York State including in Manhattan and

Westchester County. (First Amended Complaint (“FAC”) ¶ 24, ECF No. 21.) Plaintiff alleges that he and other consumers were misled to pay a premium for what they believed to be “top- quality, locally-sourced tuna caught in American waters and processed in American factories.” (FAC ¶¶ 2, 4.) But, according to Plaintiff, the tuna is not in fact caught in America and much of the tuna is canned in Thailand, Costa Rica, Vietnam and other countries. (FAC ¶¶ 5-6, 8.)

Plaintiff further alleges that Defendants’ misleading tactics are present on its website and social media platforms, as well as on the labels of the cans of tuna sold at Whole Foods. (FAC ¶¶ 9, 30.) Thus, Plaintiff accuses American Tuna of false labeling and marketing of its products. American Tuna resides in San Diego, California, where it’s offices and the majority of its employees are located. (Burton Decl. ¶¶ 3-4, 11.) It has no offices or personnel in New York. (Id. ¶¶ 16-17.) American Tuna’s records, both hard copy and digital, are located in San Diego.

(Id. ¶ 20.) Its vendors that would assist with production of records in this litigation are mostly located in California. (Id. ¶ 21.) American Tuna has identified a number of employee and officer witnesses who would testify in its defense who are located in either San Diego or the United Kingdom. (Id. ¶ 14.) The decisions regarding the labeling and marketing of American

2 For the purposes of this opinion, the Court assumes the truth of the allegations in the amended pleading. The Court also cites to two declarations of John Burton, one as the CEO of American Tuna, and the other as the CEO of WWF, which may be considered in connection with the motion to transfer. (ECF Nos. 27-28, 33.) The declarations identify witnesses and describe the corporate structure of Defendants and the location of key personnel and vendors. Tuna products and the content of its website were made out of American Tuna’s San Diego headquarters. (Id. ¶ 15.) Defendant WWF, the majority share owner of American Tuna, is a United Kingdom

corporation. (Burton WWF Decl. ¶ 3.) It does not have offices or employees in New York. (Id. ¶¶ 4-5.) It consents to jurisdiction in the Southern District of California where it’s executives frequently travel for business. (Id. ¶¶ 11-12.) It objects to jurisdiction in New York. The tuna sold under the American Tuna brand is caught in the Pacific Ocean by approximately 70 U.S. Flagged vessels based out of California (including San Diego), Oregon and

Washington. (Burton Decl. ¶¶ 8, 23, 25.) It is canned on the West Coast in the states of Washington and Oregon. (Id. ¶¶ 8, 29.) American Tuna does not maintain records of where specifically in the Pacific Ocean the tuna is caught. Rather, the fishermen who catch the tuna each maintain records as to the locations where the tuna was caught, the size and nature of the fishery where they fish in the Pacific Ocean, the pole and line method of catching the fish, and the chain of custody of tuna landed on their vessels to the canneries. (Id. ¶ 24.) American Tuna

states that it expects to call fishermen and a representative from the American Albacore Fishing Association as witnesses regarding where the fish is caught and rules concerning the recordkeeping regarding the same. These witnesses are located in San Diego or on the West Coast. (Id. ¶¶ 23-26.) American Tuna also states it would call witnesses from its packers who are located on the West Coast. (Id. ¶29.) These witnesses would have information about the origin, tracing procedures, canning and auditing of tuna canned at their facilities. (Id.)

Whole Foods is American Tuna’s primary retail outlet. (FAC ¶ 23.) New York State has the third most Whole Foods locations in the nation (26 stores). (Id.; Burton Decl. ¶ 10.) Ten percent of American Tuna’s sales come from New York. (FAC ¶ 23.) However, California has the highest number of Whole Food stores (92 stores). (Burton Decl. ¶ 10.) Whole Foods is headquartered in Austin, Texas. (Id. ¶ 32.) American Tuna expects to call witnesses from

Whole Foods who can testify about pricing of American Tuna products as compared to its competitors. (Id. ¶ 33.) Plaintiff seeks to represent a nationwide class of “all persons residing in the United States and its territories who purchased American Tuna Products during the applicable limitations period primarily for personal, family, or household purposes, and not for resale.”

(FAC ¶ 39.) The nationwide claims are premised on various tort claims including breach of express warranty, negligent misrepresentation, and unjust enrichment and would implicate the relevant laws of each state of purported class members. (FAC ¶¶ 51-73.) Plaintiff also seeks to represent a New York subclass of all consumers who purchased American Tuna products in New York. (FAC ¶ 39.) The state claims include the torts mentioned above as well as alleged violations of New York General Business Law §§ 349 & 350 for deceptive trade practices. (FAC

¶¶ 74- 98.) DISCUSSION A. Legal Standard When a party has moved to transfer and to dismiss certain claims, the court first considers the transfer motion. Peroutka v. Yeti Coolers, LLC, 2020 WL 1283148, at *2 (E.D.N.Y. Mar. 17, 2020). If the court determines that transfer is appropriate, it should defer to the

transferee court with respect to the dispositive motion. Id. Transfer of venue to another district is permitted “for the convenience of parties and witnesses” and “in the interest of justice” so long as the case might have originally been brought in the transferee district. 28 U.S.C. § 1404(a).

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Bluebook (online)
Craig v. American Tuna Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/craig-v-american-tuna-inc-nysd-2022.