Harris v. LAZ Parking LTD, LLC

District Court, D. Connecticut·Decided February 12, 2025·No. 3:24-cv-00889·Unknown

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF CONNECTICUT AMY HARRIS, individually and on behalf ) 3:24-cv-889 (SVN) of others similarly situated, ) Plaintiff, ) ) v. ) ) LAZ PARKING LTD, LLC, et al. ) Defendants. ) February 12, 2025

RULING ON DEFENDANTS’ MOTION TO DISMISS Sarala V. Nagala, United States District Judge. Plaintiff Amy Harris, individually and on behalf of others similarly situated, brings this putative consumer class action against Defendants LAZ Parking Ltd, LLC (“LAZ LTD”) and LAZ Karp Associates, LLC (“LAZ Karp”), asserting claims for breach of contract, violations of the Connecticut Unfair Trade Practices Act (“CUTPA”) and the Missouri Merchandising Practices Act (“MMPA”), and civil conspiracy related to service fees charged by Defendants. Am. Compl., ECF No. 29. The amended complaint alleges, generally, that Defendants improperly charged Plaintiff and putative class members an unauthorized service fee for parking in their lots when they paid for parking through Defendants’ online payment system. Defendants have moved to dismiss Plaintiff’s amended complaint in full for failure to state a claim. Defs.’ Mot. to Dismiss, ECF No. 34 at 1. For the reasons described herein, Defendants’ motion to dismiss is GRANTED, though Plaintiff is granted leave to amend her MMPA and civil conspiracy claims only. I. FACTUAL BACKGROUND The Court accepts the following allegations in Plaintiff’s amended complaint as true for purposes of deciding Defendants’ motion to dismiss. See Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

Defendants are Connecticut-based limited liability companies that own, operate, manage, and lease parking facilities throughout the United States. Am. Compl. ¶¶ 2, 12–13, 17. Defendant LAZ LTD is wholly owned and controlled by Defendant LAZ Karp, and the two entities share the same address as their principal place of business in Hartford, Connecticut. Id. ¶¶ 18–19. In their parking lots, Defendants post signs that display the parking rates, and in some instances applicable taxes, but do not disclose that an additional fee or surcharge may apply to the parking transaction. Id. ¶¶ 2–3, 23. Most of Defendants’ parking lots require customers to pay using an online cashless payment system that can be accessed via the LAZ mobile app1 or the LAZ website (the “Payment System”), eliminating “traditional” methods of payment such as parking attendants, meters, or ticketed gates. Id. ¶¶ 29–32. In the Payment System, customers specify the

duration of their parking session and provide their vehicle information, personal information, and credit or debit card information. Id. ¶ 33. The Payment System then calculates the cost of the parking session based on the duration of the parking session, the rate posted on the parking lot signage, and a “service fee” that is not disclosed on the signage. Id. ¶¶ 34–35. When the customer confirms the purchase by selecting the “PAY” button, she also agrees to the “Terms & Conditions, Privacy Policy and License Plate Recognition Policy,” which are linked to and contained on the LAZ app or the LAZ website. Id. ¶¶ 52–53. Further details regarding the Terms & Conditions are set forth below.

1 Defendants refer to this app as the “LAZGo App.” Defs.’ Opening Br., ECF No. 34-1 at 11 n.4. Named Plaintiff Harris is a citizen and resident of Missouri. Id. ¶ 11. On December 21, 2022, she parked in a parking lot located in Missouri, operated by Defendants. Id. ¶ 40. The signage at the parking lot specified parking rates of $6.00 for the first four hours, $12.00 for four to eight hours, and $24.00 for eight to twenty-four hours, and did not disclose anything about a

service fee. Id. at 2; id. ¶ 40. Once parked, Plaintiff accessed the Payment System to pay for four hours of parking. Id. ¶ 41. As a result of the $0.37 service fee charged for using the Payment System, Plaintiff paid a total of $6.37, rather than the posted rate of $6.00, for her four-hour session. Id. ¶ 42. In Plaintiff’s view, the posted signage is an offer, not an advertisement, and the act of parking in the lot is conduct signifying her acceptance of the offer, even before she renders payment. Id. ¶¶ 24–25. Plaintiff brings this class action on behalf of herself and all other individuals in two different classes: (1) the “Nationwide Class” and (2) the “Missouri Class.” Id. ¶ 65. The Nationwide Class constitutes “[a]ll persons who during the class period were charged a ‘Service Fee’ by Defendants for parking in a parking lot that contains a LAZ Parking sign, the terms of

which provide for parking at an hourly rate based on the duration of the parking session and do not disclose the Service Fee.” Id. The Missouri Class similarly includes customers who were charged an undisclosed service fee in Missouri. Id. Plaintiff does not specify whether the Nationwide Class includes the Missouri Class. Plaintiff brings the following claims in her amended complaint2: (1) breach of contract based on parking lot signage, individually and on behalf of the members of the Nationwide Class (Count I); (2) as an alternative to the breach of contract parking lot signage claim, breach of

2 After Defendants moved to dismiss her original complaint, see Defs.’ Mot. to Dismiss, ECF No. 22, Plaintiff timely filed an amended complaint in response. See Fed. R. Civ. P. 15(a)(1)(B). Defendants thereafter moved to dismiss Plaintiff’s amended complaint. contract based on the Terms & Conditions, individually and on behalf of the members of the Nationwide Class (Count II); (3) per se violations of CUTPA, individually (Count III); (4) violation of the MMPA, individually and on behalf of the members of the Missouri Class (Count IV); and (5) civil conspiracy, individually and on behalf of the members of an unspecified class (Count V).3 Id. at 15–20.

II. LEGAL STANDARD Pursuant to Federal Rule of Civil Procedure 12(b)(6), a defendant may move to dismiss a case or cause of action for failure to state a claim upon which relief can be granted. When determining whether a complaint states a claim upon which relief can be granted, highly detailed allegations are not required, but the complaint must “contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is plausible on its face.’” Iqbal, 556 U.S. at 678 (quoting Bell Atl. Corp. v. Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Id. This plausibility standard is not a “probability

requirement,” but imposes a standard higher than “a sheer possibility that a defendant has acted unlawfully.” Id. In undertaking this analysis, the Court must “draw all reasonable inferences in [the plaintiff’s] favor, assume all well-pleaded factual allegations to be true, and determine whether they plausibly give rise to an entitlement to relief.” Faber v. Metro. Life Ins. Co., 648 F.3d 98, 104 (2d Cir. 2011) (internal quotation marks omitted). However, the Court is not “bound to accept conclusory allegations or legal conclusions masquerading as factual conclusions,” id., and “a formulaic recitation of the elements of a cause of action will not do,” Iqbal, 556 U.S. at 678. Consequently, “[t]hreadbare recitals of the elements

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Harris v. LAZ Parking LTD, LLC, (D. Conn. 2025).

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