Fitzgerald v. The Shade Store LLC

CourtDistrict Court, W.D. Washington
DecidedJuly 25, 2024
Docket2:23-cv-01435
StatusUnknown

This text of Fitzgerald v. The Shade Store LLC (Fitzgerald v. The Shade Store 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
Fitzgerald v. The Shade Store LLC, (W.D. Wash. 2024).

Opinion

3 UNITED STATES DISTRICT COURT 4 WESTERN DISTRICT OF WASHINGTON 5 AT SEATTLE

6 7 LEE FITZGERALD, individually and on Case No. C23-1435RSM behalf of all others similarly situated,

8 Plaintiff, ORDER DENYING MOTION TO 9 DISMISS v. 10

11 THE SHADE STORE, LLC,

12 Defendant.

14 I. INTRODUCTION 15 This matter comes before the Court on Defendant The Shade Store, LLC’s Motion to 16 Dismiss, Dkt. #30. The Shade Store argues that Plaintiff Lee Fitzgerald’s claims should be 17 dismissed for failing to adequately allege damages and for other certain reasons, and that 18 Plaintiff’s nationwide class allegations should be dismissed for lack of standing. Plaintiff has 19 20 filed an opposition, Dkt. #37. The Court has determined that it can rule without the need of 21 oral argument. For the reasons stated below, the Court DENIES The Shade Store’s Motion. 22 II. BACKGROUND 23 For purposes of this 12(b)(6) Motion, the Court will accept all facts in the First 24 25 Amended Complaint, Dkt. #29, as true. The Court will briefly summarize the relevant facts. 26 Defendant The Shade Store is a Delaware company that makes, sells, and markets 27 blinds, shades, and other window covering products through its website, 28 www.theshadestore.com. On February 27, 2022, Plaintiff Fitzgerald purchased a set of cellular shades from 1 2 Defendant’s website. She made this purchase while living in Seattle, Washington. 3 This purchase occurred during an advertised sale. On February 18, 2022, Defendant 4 stated on its website that a “20% OFF ALL ORDERS” sale was running through the date of 5 Ms. Fitzgerald’s purchase until “3/2.” Defendant represented that the list price of the Product 6 that Ms. Fitzgerald purchased was $640.00 and that Ms. Fitzgerald was receiving a discount of 7 8 $128.00. Defendant confirmed this in an email it sent to Ms. Fitzgerald after she made her 9 purchase. Ms. Fitzgerald includes screenshots of all of this in her Complaint. 10 Ms. Fitzgerald alleges she read and relied on the above representations from the website 11 and email confirmation, specifically that her shades were being offered at a discount for a 12 13 limited time and had a higher regular price, and that she would be receiving a price reduction. 14 Plaintiff alleges that The Shade Store “creates an illusion” that customers are receiving 15 a limited-time discount “by advertising fake limited-time sales, fake regular prices, and fake 16 discounts based on the fake regular prices.” Dkt. #29 at 8. These discounts are advertised as 17 available for a limited time, however immediately after each sale ends Defendant generates 18 19 another similar or identical discount, with a new expiration date. Examples screenshots 20 showing a 20% off sale continuing after the end date are included in the Amended Complaint. 21 See id. at 17. According to the allegations, the shades are never sold at non-sale prices. 22 Plaintiff alleges that the above is deceptive and unfair and induced her to make a 23 purchase that she would not otherwise have made. She alleges that she and others in the 24 25 proposed class “received Products with market values lower than the promised market values.” 26 Id. at ¶ 84. 27

28 The Amended Complaint brings claims for: violation of the Washington Consumer 1 2 Protection Act (“CPA”); breach of contract; breach of express warranty; quasi-contract/unjust 3 enrichment; and intentional misrepresentation. Plaintiff seeks actual and punitive damages. 4 III. DISCUSSION 5 A. Legal Standard under Rule 12(b)(6) 6 In making a 12(b)(6) assessment, the court accepts all facts alleged in the complaint as 7 8 true, and makes all inferences in the light most favorable to the non-moving party. Baker v. 9 Riverside County Office of Educ., 584 F.3d 821, 824 (9th Cir. 2009) (internal citations omitted). 10 However, the court is not required to accept as true a “legal conclusion couched as a factual 11 allegation.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atl. Corp. v. Twombly, 12 13 550 U.S. 544, 555 (2007)). The complaint “must contain sufficient factual matter, accepted as 14 true, to state a claim to relief that is plausible on its face.” Id. at 678. This requirement is met 15 when the plaintiff “pleads factual content that allows the court to draw the reasonable inference 16 that the defendant is liable for the misconduct alleged.” Id. The complaint need not include 17 detailed allegations, but it must have “more than labels and conclusions, and a formulaic 18 19 recitation of the elements of a cause of action will not do.” Twombly, 550 U.S. at 555. Absent 20 facial plausibility, a plaintiff’s claims must be dismissed. Id. at 570. 21 B. Analysis 22 As an initial matter, the Court notes that the legal theories at issue here are familiar to 23 the Court and to this Defendant in particular. The Shade Store has been sued in California by a 24 25 different consumer for essentially the same conduct at issue. That lawsuit asserts materially 26 identical claims both in common law and under a similar state statute, Defendant moved to 27 dismiss, and the Court denied that Motion in part. See Crowder v. Shade Store, LLC, 2024 U.S. 28 Dist. LEXIS 41896 (N.D. Cal. Feb. 12, 2024). Plaintiffs in that case amended the complaint, 1 2 Defendant again moved to dismiss, and the Court denied the motion to dismiss the state 3 statutory claims, intentional misrepresentation, and punitive damages claims, but dismissed the 4 quasi-contract/unjust enrichment and negligent misrepresentation claims. Crowder v. The 5 Shade Store, LLC, Case No. 23-cv-02331-NC, Dkt. #69 (N.D. Cal. June 26, 2024). 6 This type of “fake discount” case has also been tried here as a violation of 7 8 Washington’s CPA. “Inducing a plaintiff into spending money she otherwise would not have 9 spent, based on a misrepresentation, is clearly a cognizable injury” under the CPA. Nemykina 10 v. Old Navy, LLC, 461 F. Supp. 3d 1054, 1061 (W.D. Wash. 2020). 11 Considering the above, the Court finds that Plaintiff’s claims are generally plausible 12 13 where sufficient facts have been alleged. The Court will go through the facts of each claim 14 below. 15 1. CPA Claim 16 The Shade Store first moves to dismiss Plaintiff’s CPA claim for failure to adequately 17 allege a cognizable injury or that it engaged in an unfair act or deceptive practice. A CPA 18 19 claim requires a plaintiff to allege “(1) ... an unfair or deceptive act or practice, (2) in trade or 20 commerce, (3) that impacts the public interest, (4) resulting in injury to business or property, 21 and (5) a causal link between the unfair or deceptive practice and the injury suffered.” RCW 22 19.86.020; Hangman Ridge Training Stables, Inc. v. Safeco Title Ins. Co., 105 Wn.2d 778, 784- 23 85, 719 P.2d 531 (1986). 24 25 The Amended Complaint is fairly detailed and specific as to the circumstances of 26 Plaintiff’s shades purchase. Plaintiff alleges that “Defendant’s advertisements harm consumers 27 by inducing them to make purchases they otherwise would not have made, based on false 28 information,” Dkt. #29 at ¶ 49, and that she herself “would not have made the purchase if she 1 2 had known that the Product was not discounted as advertised, and that she was not receiving 3 the advertised discount,” id. at ¶ 54. She also alleges that “due to Defendant’s 4 misrepresentations, [she] and the class paid more for the Products they bought than they 5 otherwise would have.” Id. at ¶ 49.

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Fitzgerald v. The Shade Store LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/fitzgerald-v-the-shade-store-llc-wawd-2024.