Cole v. Amazon.com Services LLC

CourtDistrict Court, W.D. Washington
DecidedFebruary 6, 2025
Docket2:24-cv-01147
StatusUnknown

This text of Cole v. Amazon.com Services LLC (Cole v. Amazon.com Services LLC) is published on Counsel Stack Legal Research, covering District Court, W.D. Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cole v. Amazon.com Services LLC, (W.D. Wash. 2025).

Opinion

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5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 DEON COLE, CASE NO. 2:24-cv-01147-TL 12 Plaintiff, ORDER ON MOTION TO DISMISS v. 13 AMAZON.COM SERVICES LLC, et al., 14 Defendants. 15

16 17 This is a case stemming from an incident where a delivery driver allegedly took 18 unauthorized photographs of a customer’s home while delivering groceries to the customer. This 19 matter comes before the Court on Defendants’ motion to dismiss. Dkt. No. 37. Having reviewed 20 the motion, Plaintiff’s response (Dkt. No. 40), Defendants’ reply (Dkt. No. 43), and the relevant 21 record, the Court GRANTS Defendants’ motion with leave to amend. 22 I. BACKGROUND 23 Plaintiff is Deon Cole, an actor and comedian who describes himself as a “well-known 24 celebrity.” Dkt. No. 32 (Amended Complaint) ¶ 4.16. Defendants are Amazon.com Services 1 LLC (“Amazon”) and Amazonfresh LLC (“Fresh”), as well as 20 unnamed John Does. Id. 2 ¶¶ 2.2–2.4. 3 On April 20, 2022, Plaintiff placed an order for grocery delivery from Defendant Fresh. 4 Id. ¶ 4.1. Later that day, a driver—an employee of Defendant Fresh—arrived at Plaintiff’s

5 residence to deliver the groceries. Id. ¶¶ 4.2–4.3. When Plaintiff answered the door, the driver 6 advised Plaintiff that he needed to see Plaintiff’s identification to complete the delivery. Id. ¶ 4.3. 7 Plaintiff went to retrieve his driver’s license but left the door to his house “partially open.” Id. 8 ¶ 4.4. When Plaintiff returned with his license, he found the driver “taking unauthorized photos 9 of the inside of his home from the doorstep.” Id. ¶ 4.5. Plaintiff asked the driver to stop taking 10 pictures and began to record the driver’s actions with his phone. Id. ¶¶ 4.6–4.7. The two then 11 “exchanged several words,” with the driver initially denying that he had taken any photographs. 12 Id. ¶¶ 4.8–4.9. After Plaintiff advised that he had seen a photo on the screen of the driver’s 13 electronic device, the driver agreed to delete the photos from the device. Id. ¶¶ 4.8–4.9. After the 14 driver left, Plaintiff reviewed the video recording of the incident that he had made on his phone.

15 Id. ¶ 4.11. “The recording showed the delivery person’s phone screen and a group chat in which 16 photos of [Plaintiff’s] house were shared.” Id. Plaintiff contacted Defendant Amazon to complain 17 but was dissatisfied with the company’s response. Id. ¶¶ 4.13–4.14. 18 The incident left Plaintiff “troubled and in constant distress over his safety while in the 19 privacy of his home.” Id. ¶ 4.15. Plaintiff engaged in “multiple therapy sessions” and installed a 20 new home security system for his residence. Id. ¶¶ 4.15, 4.18. Finally, some 18 months 21 afterward, on October 28, 2023, there was an attempted burglary on Plaintiff’s home, which the 22 new security system thwarted. Id. ¶ 4.19. 23 On March 28, 2024, Plaintiff filed a California state-law complaint against Defendants in

24 Los Angeles County Superior Court, alleging negligence, intentional infliction of emotional 1 distress, and breach of contract. Dkt. No. 1-1. Defendants removed the case to United States 2 District Court for the Central District of California (Dkt. No. 1), then moved to transfer the case 3 to the Western District of Washington pursuant to 28 U.S.C. § 1404(a) and a forum-selection 4 clause in the Amazon.com Conditions of Use (Dkt. No. 8). Plaintiff opposed the motion, but on

5 July 26, 2024, U.S. District Judge André Birotte Jr. granted Defendants’ motion. Dkt. No. 21. 6 On September 26, 2024, Plaintiff filed an Amended Complaint in this Court. Dkt. No. 32. 7 Now brought under Washington law, the Amended Complaint—now the operative complaint in 8 this matter—alleges negligence, outrage, invasion of privacy, and breach of contract. Id. ¶¶ 5.1– 9 8.7. On November 1, 2024, Defendants filed the instant motion to dismiss. Dkt. No. 37. Plaintiff 10 opposes (Dkt. No. 40), and Defendants filed a reply (Dkt. No. 43). 11 II. LEGAL STANDARD 12 A defendant may seek dismissal when a plaintiff fails to state a claim upon which relief 13 can be granted. Fed. R. Civ. P. 12(b)(6). In reviewing a Rule 12(b)(6) motion to dismiss, the 14 Court takes all well-pleaded factual allegations as true and considers whether the complaint

15 “state[s] a claim to relief that is plausible on its face.” Ashcroft v. Iqbal, 556 U.S. 662, 678 16 (2009) (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). While “[t]hreadbare 17 recitals of the elements of a cause of action, supported by mere conclusory statements,” are 18 insufficient, a claim has “facial plausibility” when the party seeking relief “pleads factual content 19 that allows the court to draw the reasonable inference that the defendant is liable for the 20 misconduct alleged.” Iqbal, 556 U.S. at 672. “When reviewing a dismissal pursuant to Rule 21 12(b)(6), “‘we accept as true all facts alleged in the complaint and construe them in the 22 light most favorable to plaintiff[ ], the non-moving party.’” DaVinci Aircraft, Inc. v. United 23 States, 926 F.3d 1117, 1122 (9th Cir. 2019) (alteration in original) (quoting Snyder & Assocs.

24 Acquisitions LLC v. United States, 859 F.3d 1152, 1156–57 (9th Cir. 2017)). 1 III. DISCUSSION 2 As stated above, the Amended Complaint includes four causes of action, all brought 3 under Washington state law: negligence, outrage, invasion of privacy, and breach of contract. 4 Dkt. No. 32 ¶¶ 5.1–8.7. The Court examines each in turn.

5 A. First Cause of Action: Negligence 6 Defendants observe that Plaintiff “groups four different negligence claims into one 7 general negligence claim.” Dkt. No. 37 at 8; see Dkt. No. 32 ¶ 5.5. The Court agrees with this 8 description and construes the “group[ed]” negligence claim as comprising separate claims for 9 negligent hiring, negligent training, negligent supervision, and negligent retention. 10 1. Hiring, Training, and Supervision 11 As to negligent hiring, training, and supervision, Defendants point out that these claims 12 necessarily fail as a matter of law, because “Plaintiff fails to allege that the driver acted outside 13 the scope of his employment.” Dkt. No. 37 at 9 (underscore in original). The Court agrees. In 14 Washington, “negligent hiring, training, and supervision claims against an employer require that

15 the employee ‘acted outside the scope of his or her employment.’” Lidstrom v. Scotlynn 16 Commodities Inc., No. C23-1544, 2024 WL 2886570, at *2 (E.D. Wash. June 6, 2024) (quoting 17 LaPlant v. Snohomish County, 162 Wn. App. 476, 479, 271 P.3d 254 (2011)). 18 In his Amended Complaint, Plaintiff alleges that, “At all relevant times herein the driver, 19 while in the scope of his employment for Amazon and Fresh, intended to invade the privacy of 20 [Plaintiff’s] home and/or obtain unauthorized photographs of the inside of [Plaintiff’s] 21 residence.” Dkt. No. 32 ¶ 5.4 (emphasis added). Plaintiff argues in his response that the Court 22 should discount the language of the pleading, as it is merely “a play on words” (Dkt. No. 40 at 23 5)—but the Court fails to see the game and instead takes the allegations at face value. They are

24 straightforward, pleaded in plain and declarative language, and crafted by legal counsel.

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Cole v. Amazon.com Services LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cole-v-amazoncom-services-llc-wawd-2025.