Brandon Meyers v. Target Corporation and John Does 1–10

Summary

The court partially granted and partially denied Target Corporation’s motion to dismiss claims arising from Brandon Meyers’s termination and alleged workplace sexual harassment. The court dismissed Meyers’s Montana Human Rights Act claims with prejudice, denied dismissal of his Title VII claims because they related back to the original complaint, and dismissed his Wrongful Discharge from Employment Act claim without prejudice with leave to amend. The order was issued by the United States District Court for the District of Montana on February 10, 2026.

Holdings

1. The court could take judicial notice of the MHRB and EEOC right-to-sue letters because they were issued by government agencies and their authenticity was not disputed, without converting the motion to dismiss into a motion for summary judgment. Judicial notice of the administrative charges was limited to their existence, filing dates, and the fact that particular allegations were made.
2. Meyers's MHRA claims were untimely and had to be dismissed with prejudice because he filed his original complaint after the 90-day period following the MHRB's dismissal and right-to-sue notice.
3. Meyers's Title VII discrimination and retaliation claims in the amended complaint related back to the original complaint under Rule 15(c)(1)(B) and therefore were not time-barred.
4. The WDEA claim was not subject to dismissal at this stage merely because Meyers also asserted MHRA claims. Simultaneous WDEA and MHRA claims may proceed when the WDEA claim is based on non-discriminatory conduct separate and distinct from the conduct supporting the MHRA claim; if the court later determines that the discharge resulted from sex-based discrimination, the WDEA claim must be dismissed.
5. The WDEA claim failed to state a claim because it consisted largely of legal conclusions and lacked sufficient factual context, but dismissal was without prejudice and with leave to amend because additional facts might cure the deficiency.

Questions Presented

1. Whether Meyers's MHRA claims were barred because he did not commence a civil action within 90 days after the Montana Human Rights Bureau issued its dismissal and right-to-sue notice.
2. Whether Meyers's Title VII discrimination and retaliation claims in the amended complaint related back to the timely original complaint under Federal Rule of Civil Procedure 15(c).
3. Whether Meyers's WDEA claim was barred by the MHRA's exclusivity provisions or instead failed because it lacked sufficient factual allegations.
4. Whether the court could take judicial notice of administrative right-to-sue letters and charges without converting the Rule 12(b)(6) motion into one for summary judgment.

Disposition

other