Barnes v. Key Tronic Corporation

CourtDistrict Court, E.D. Washington
DecidedAugust 19, 2025
Docket2:25-cv-00081
StatusUnknown

This text of Barnes v. Key Tronic Corporation (Barnes v. Key Tronic Corporation) is published on Counsel Stack Legal Research, covering District Court, E.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Barnes v. Key Tronic Corporation, (E.D. Wash. 2025).

Opinion

1 FILED IN THE 2 U.S. DISTRICT COURT EASTERN DISTRICT OF WASHINGTON Aug 19, 2025 3 SEAN F. MCAVOY, CLERK 4 5 UNITED STATES DISTRICT COURT EASTERN DISTRICT OF WASHINGTON 6

7 CHASE BARNES, on behalf of himself individually and all others NO. 2:25-CV-0081-TOR 8 similarly situated, Plaintiff, ORDER GRANTING IN PART 9 DEFENDANT’S MOTION TO v. DISMISS 10 KEY TRONIC CORPORATION, a 11 Washington corporation, Defendant. 12

13 BEFORE THE COURT is Defendant’s Motion to Dismiss (ECF No. 10). 14 The Court has reviewed the record and files herein, determined that oral argument 15 is unnecessary, and is fully informed. For the reasons discussed below, 16 Defendant’s Motion to Dismiss (ECF No. 10) is GRANTED in part. 17 BACKGROUND 18 This matter arises out of a data breach which resulted in the compromise of 19 Plaintiff’s personally identifiable information (“PII”). Plaintiff, a citizen of 20 Alabama, was employed with Defendant, a Washington corporation that designs 1 and manufactures precision injection molding products, with locations in 2 Washington, Texas, Arkansas, Minnesota, and Mississippi. ECF No. 1 at 7, 36, ¶¶

3 23, 107. Plaintiff was working at Defendant’s manufacturing facility in 4 Mississippi when he learned that his PII provided to his employer had likely been 5 stolen in a May 2024 data breach. Id. at 36, ¶ 106. Plaintiff received a notice from

6 Defendant in July 2023 stating that the company had experienced a data breach by 7 cybercriminals, and that his name and social security number was among the 8 material stolen. Id. at 60. He and other employees had provided this information 9 to Defendant as a condition of employment. Id. at 7, ¶ 24. Defendant offered two

10 years of credit monitoring in response to the breach. Id. at 37, ¶ 114. Since the 11 breach, Plaintiff has undertaken monitoring of his credit information and suffers 12 from fear, anxiety, and stress. Id. at 39–40, ¶ 137.

13 Plaintiff filed the present lawsuit on behalf of himself and similarly situated 14 individuals, bringing claims of negligence, breach of implied contract, breach of 15 fiduciary duty, and unjust enrichment. ECF No. 1. Defendant has filed this 16 motion to dismiss, arguing that Plaintiff lacks standing, and that even if he has

17 standing, his claims are untenable. ECF No. 11. 18 DISCUSSION 19 I. Article III Standing

20 Defendant challenges Plaintiff’s standing to bring suit, arguing that he has 1 not alleged an injury in fact or a concrete risk of future harm. ECF No. 10 at 11‒ 2 12. A jurisdictional challenge brought under Rule 12(b)(1) may present as either a

3 facial or factual attack. White v. Lee, 227 F.3d 1214, 1242 (9th Cir. 2000). “In a 4 facial attack, the challenger asserts that the allegations contained in a complaint are 5 insufficient on their face to invoke federal jurisdiction. By contrast, in a factual

6 attack, the challenger disputes the truth of the allegations that, by themselves, 7 would otherwise invoke federal jurisdiction.” Safe Air for Everyone v. Meyer, 373 8 F.3d 1035, 1039 (9th Cir. 2004). The court “resolves a facial attack as it would a 9 motion to dismiss under Rule 12(b)(6): Accepting the plaintiff's allegations as true

10 and drawing all reasonable inferences in the plaintiff's favor, the court determines 11 whether the allegations are sufficient as a legal matter to invoke the court's 12 jurisdiction.” Leite v. Crane Co., 749 F.3d 1117, 1121 (9th Cir. 2014) (citation

13 omitted). 14 Article III of the United States Constitution vests in federal courts the power 15 to entertain disputes over “cases” or “controversies.” U.S. CONST. art. III, § 2. 16 To satisfy the case or controversy requirement, and thereby show standing, a

17 plaintiff must demonstrate that throughout the litigation, they suffered, or will be 18 threatened with, an actual injury traceable to the defendant which will likely be 19 redressed by a favorable judicial decision. Spencer v. Kemna, 523 U.S. 1, 7 (1998)

20 (quoting Lewis v. Cont'l Bank Corp., 494 U.S. 472, 477 (1990)); see also Deakins 1 v. Monaghan, 484 U.S. 193, 199 (1988) (“Article III of the Constitution limits 2 federal courts to the adjudication of actual, ongoing cases or controversies between

3 litigants.”). Three elements must be shown in order to establish Article III 4 standing: (1) the plaintiff must have suffered an “injury in fact” which is both 5 concrete and particularized and not “conjectural” or “hypothetical”; (2) there must

6 be a causal connection between the injury and the conduct complained of; and (3) 7 it must be “likely” as opposed to “speculative” that the injury will be “redressed by 8 a favorable decision.” Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992) 9 (internal citations and quotations omitted). The party invoking federal jurisdiction

10 bears the burden of establishing the elements. Id. at 561 (citing FW/PBS, Inc. v. 11 Dallas, 493 U.S. 215, 231 (1990)). However, “[a]t the pleading stage, general 12 factual allegations of injury resulting from the defendant's conduct may suffice.”

13 Lujan, 504 U.S. at 561. 14 “[A] 12(b)(1) motion to dismiss for lack of standing can only succeed if the 15 plaintiff has failed to make ‘general factual allegations of injury resulting from the 16 defendant's conduct.’” Id. Further, “in determining constitutional standing, ‘it is

17 within the trial court's power to allow or to require the plaintiff to supply, by 18 amendment to the complaint or by affidavits, further particularized allegations of 19 fact deemed supportive of plaintiff's standing.’” Maya v. Centex Corp., 658 F.3d

20 1060, 1067 (9th Cir. 2011) (quoting Warth v. Seldin, 422 U.S. 490, 501 (1975)). 1 The burden of proof rests with the party invoking federal jurisdiction, and the party 2 must support the elements of standing “with the manner and degree of evidence

3 required at the successive stages of the litigation.” Lujan, 504 U.S. at 561. 4 Here, Defendant challenges that injury-in-fact portion of standing, arguing 5 that any injury Plaintiff (and the class that may be formed) alleges is too abstract to

6 support his claims. ECF No. 10 at 12. The Court agrees in part. An injury in fact 7 must be concrete, and absent this demonstration, a plaintiff does not have standing. 8 TransUnion LLC v. Ramirez, 594 U.S. 413, 417 (2021). Concrete injuries can be 9 tangible, like monetary loss or physical harms, or they may be intangible, which

10 the Supreme Court has noted as those which have a “close relationship to a harm 11 that has traditionally been regarded as providing a basis for a lawsuit in English or 12 American courts.” Spokeo, Inc. v. Robins, 578 U.S. 330, 341 (2016). The Court

13 has described these traditional bases as causes of action for things like intrusion 14 upon seclusion, public disclosure of private fact, and reputational damage. 15 TransUnion LLC, 594 U.S. at 425. However, future harms cannot form the basis 16 of a concrete injury “unless the exposure to the risk of future harm itself causes a

17 separate concrete harm.” Id. at 436. 18 Plaintiff argues that he has alleged an injury in fact because he faces a future 19 risk of harm related to the leak of his personal data and has spent time and money

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Barnes v. Key Tronic Corporation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/barnes-v-key-tronic-corporation-waed-2025.