Drake v. Haier US Appliance Solutions Inc.

CourtDistrict Court, N.D. California
DecidedFebruary 13, 2024
Docket3:23-cv-00939
StatusUnknown

This text of Drake v. Haier US Appliance Solutions Inc. (Drake v. Haier US Appliance Solutions Inc.) is published on Counsel Stack Legal Research, covering District Court, N.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Drake v. Haier US Appliance Solutions Inc., (N.D. Cal. 2024).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 CHARLES DRAKE, Case No. 23-cv-00939-AMO

8 Plaintiff, ORDER GRANTING IN PART AND 9 v. DENYING IN PART DEFENDANT’S MOTION TO DISMISS 10 HAIER US APPLIANCE SOLUTIONS INC., Re: Dkt. No. 20 11 Defendant.

12 13 Defendant Haier US Appliance Solutions Inc.’s motion to dismiss was heard before this 14 Court on August 10, 2023. Having read the papers filed by the parties and carefully considered 15 their arguments therein and those made at the hearing, as well as the relevant legal authority, the 16 Court hereby GRANTS the motion in part and DENIES the motion in part for the following 17 reasons. 18 BACKGROUND 19 The Complaint makes the following allegations, which the Court accepts as true for 20 purposes of the motion to dismiss. See Usher v. City of Los Angeles, 828 F.2d 556, 561 (9th Cir. 21 1987). Plaintiff Charles Drake lives in McKinleyville, California. Compl. ¶ 6. In November 22 2022, Drake purchased a GE gas stove manufactured by Defendant and sold through a third-party 23 retailer. Compl. ¶ 38. Defendant Haier US Appliance Solutions, Inc. (“Haier”) makes, distributes, 24 sells, and markets gas stoves, ovens, and range products, including under the GE brand. Compl. 25 ¶ 8. Haier is a Delaware corporation with a principal place of business in Louisville, Kentucky. 26 Compl. ¶ 9. 27 Drake contends that Haier misleads consumers into believing that gas stoves are generally 1 See Compl. ¶¶ 1, 4, 32-33, 37, 41. Although “[a]bout 40% of American households use natural 2 gas stoves,” they have a “defect” because they purportedly emit “air pollutants . . . linked to 3 respiratory illness, cardiovascular problems, cancer, and other health conditions.” Compl. ¶¶ 1, 4 32-33. Haier knew that gas stoves and related products emit health-harming pollutants. Compl. 5 ¶¶ 22-27. Moreover, Haier was aware of safe, reasonable alternative designs that would avoid or 6 reduce the harmful pollutants emitted by gas stoves. Compl. ¶¶ 28-29. 7 Haier should have warned consumers of the pollutant risks, Drake contends. Compl. 8 ¶¶ 30-33. If Haier had included such a warning, demand for gas stoves and related products would 9 decrease, leading to a decrease in price – this failure to disclose the risks artificially inflates the 10 price of gas stoves, leading Drake and other consumers to overpay for the products and suffer 11 damages. Compl. ¶¶ 34-37. 12 Drake does not allege that he or his family have been physically harmed by the gas stove 13 he purchased. Drake does not state anything specific about his gas stove or its emissions. Rather, 14 Drake’s and the putative class’s damages are premised on the economic loss of overpaying for gas 15 stoves that would have been cheaper if the public had not been gaslit and knew of the stoves’ 16 inherent danger. 17 Drake filed the operative complaint on March 2, 2023. ECF 1. He seeks to represent the 18 following classes: 19 • Nationwide Class: all persons who purchased Defendant’s Products while living in the 20 United States during the applicable statute of limitations. 21 • California Subclass: all persons who, while living in the state of California, purchased 22 Defendant’s Products during the applicable statute of limitations; and 23 • Consumer Protection Subclass: all persons who, while living in certain identified states 24 (the “Consumer Protection Subclass States”), purchased Defendant’s Products States 25 during the applicable statute of limitations. 26 Compl. ¶ 47. 27 Drake alleges the following causes of action on behalf of himself and the California sub- 1 1. Violation of California’s Unfair Competition Law (“UCL”) (including each prong, 2 unlawful, fraudulent, and unfair) 3 2. Violation of California’s False Advertising Law (“FAL”) 4 3. Violation of California’s Consumer Legal Remedies Act (“CLRA”) 5 4. Breach of implied warranty pursuant to California’s Song-Beverly Consumer Warranty 6 Act 7 Drake alleges the following causes of action on behalf of himself and the nationwide class: 8 5. Violations of State Consumer Protection Statutes in California, Connecticut, Illinois, 9 Maryland, Missouri, and New York 10 6. Breach of implied warranties under the Uniform Commercial Code 11 a. Implied warranty of merchantability (UCC § 2-314) 12 b. Implied warranty of fitness (UCC § 2-315) 13 7. Fraudulent Omission 14 8. Unjust Enrichment / Quasi-contract 15 Haier filed the instant motion to dismiss on May 3, 2023. ECF 20. Haier filed a request 16 for judicial notice in support of the motion (ECF 20-1), which the Court considers before reaching 17 the merits of the motion. 18 REQUEST FOR JUDICIAL NOTICE 19 Haier requests that the Court take judicial notice of the following documents in support of 20 the motion (ECF 20-1): 21 a. US Energy Information Administration, Highlights for appliances in U.S. homes by state, 22 2020 (Final data release: March 2023). 23 b. US Consumer Product Safety Commission, Statement of Chair Alexander Hoehn-Saric 24 Regarding Gas Stoves (Jan. 11, 2023). 25 c. US Consumer Product Safety Commission, Request for Information on Chronic Hazards 26 Associated With Gas Ranges and Proposed Solutions (Mar. 7, 2023). 27 d. GE Appliances, Single Oven Gas Ranges Owner’s Manual. 1 Federal Rule of Evidence 201 permits a court to notice a fact if it is “not subject to 2 reasonable dispute.” Fed. R. Evid. 201(b). A fact is “not subject to reasonable dispute” if it is 3 “generally known,” or “can be accurately and readily determined from sources whose accuracy 4 cannot reasonably be questioned.” Fed. R. Evid. 201(b)(1)-(2). Under the incorporation by 5 reference doctrine, the court has discretion to consider on a motion to dismiss “documents whose 6 contents are alleged in a complaint and whose authenticity no party questions, but which are not 7 physically attached to the [plaintiff’s] pleading.” Davis v. HSBC Bank Nevada, N.A., 691 F.3d 8 1152, 1160 (9th Cir. 2012); see also United States v. Ritchie, 342 F.3d 903, 908 (9th Cir. 2003) 9 (“Even if a document is not attached to a complaint, it may be incorporated by reference into a 10 complaint if the plaintiff refers extensively to the document or the document forms the basis of the 11 plaintiff’s claim.”). 12 Haier does not argue that the government reports are incorporated into the complaint by 13 reference, nor does Haier provide any reasoning why the Court should consider these materials in 14 conjunction with the motion to dismiss. Haier merely suggests that the Court can take notice of 15 these materials because they are government reports. Haier seems to offer these items in aid of its 16 factual assertion that its gas stoves are perfectly safe and that evidence to the contrary is flawed. 17 This improperly disputes the pleaded facts and draws all inferences in Defendant’s own favor. 18 See, e.g., In re Splunk Inc. Sec. Litig., 592 F. Supp. 3d 919, 946 (N.D. Cal. 2022) (rejecting the 19 defendant’s argument because it “is subject to a reasonable dispute, and the Court may not resolve 20 factual disputes at the pleading stage”); Khoja v. Orexigen Therapeutics, Inc., 899 F.3d 988, 1003 21 (9th Cir. 2018) (reaffirming “the prohibition against resolving factual disputes at the pleading 22 stage”).

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Drake v. Haier US Appliance Solutions Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/drake-v-haier-us-appliance-solutions-inc-cand-2024.