In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation

CourtDistrict Court, N.D. Illinois
DecidedFebruary 19, 2025
Docket1:23-cv-00818
StatusUnknown

This text of In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation (In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

IN RE: HAIR RELAXER MARKETING MDL No. 3060 SALES PRACTICES AND PRODUCTS LIABILITY LITIGATION Master Docket No. 23-cv-0818

Judge Mary M. Rowland

MEMORANDUM OPINION AND ORDER Before the Court are Defendants Wella Operations US, LLC and Wella AG’s (“Defendant” or “Wella”) Motions to Dismiss Under Rule 12(b)(6). [757–762]. For the reasons stated herein, Wella’s motions are denied.1 I. Background2 The factual allegations from the Master Long Form Complaint brought against Wella ([676], (“Master Complaint”)) and Short Form Complaint ([175-1], (“SFC”)) are accepted as true for the purposes of the motion to dismiss. See Lax v. Mayorkas, 20 F.4th 1178, 1181 (7th Cir. 2021).3

1 Wella’s reply in support of its motion to dismiss was due by September 30, 2024. [770]. Wella filed its reply on October 9, 2024 without leave for an extension. See [880]. Nevertheless, the Court considers Wella’s arguments in full.

2 The Court incorporates the Background section of its Memorandum Opinion and Order [291] granting in part and denying in part Defendants’ Joint Motion to Dismiss and Defendant McBride’s Motion to Dismiss Plaintiffs’ Master Long Form Personal Injury Complaint [106].

3 The Court adopted the short form complaint on August 3, 2023. Pursuant to the Court’s Case Management Order (“CMO”) No. 7, “[f]or each action in the MDL, subject to this Order, the Master Complaint, together with the Short Form Complaint shall be deemed the On May 15, 2023, Plaintiffs filed a Master Long Form Complaint against numerous other Defendants (“Phase I Defendants”), not including Wella, in this multidistrict litigation. [106]. Plaintiffs alleged they suffered personal injuries and

death as a result of their use of defective hair relaxers designed, manufactured, sold, distributed, and marketed by the Defendants named in the May 15, 2023 Master Long Form Complaint. Id. ¶¶ 5, 10. The Phase I Defendants argued the Master Long Form Complaint did not state any claim and moved to dismiss the complaint in its entirety. [142]. Although the Court dismissed claims of negligent misrepresentation, fraud/fraudulent misrepresentation, fraudulent concealment, and fraud-based claims

of deceptive acts or practices under consumer law statutes, Plaintiffs’ remaining 12 claims were permitted to proceed. [291]. On May 28, 2024, Plaintiffs filed the Master Complaint against Wella after multiple individual Plaintiffs identified on their SFCs that they use or used Wella’s hair relaxer products. [676]. The Master Complaint states Wella’s hair relaxer products include Texture & Tones, Gentle Treatment, and UltraSheen. Id. ¶ 2. Plaintiffs allege their frequent use of Wella’s hair-relaxing products caused them to

develop ovarian cancer, uterine cancer, or endometrial cancer. Id. ¶¶ 1, 6–7, 9. The Master Complaint brings the same surviving claims as the May 15, 2023 Complaint and avers substantially similar contentions. Compare [106] with [676]. Wella filed substantially identical motions to dismiss in three cases: (a) Civil Action No. 1:23-cv- 11227 filed by Plaintiff Lanisha Davis; (b) Civil Action No. 1:23-cv-10476 filed by

operative complaint.” [175] at 1. This opinion sometimes refers to the Master Complaint and SFC together as the “Complaint.” Plaintiff Mamie Irvin; and (c) Civil Action No. 1:23-cv-08237 filed by Plaintiffs Dawn and Rodney Hall, Sr.. On February 17, 2025, Wella Operations US, LLC moved to adopt and join any cases newly filed against Wella and any cases prospectively filed

against Wella in its original motion to dismiss. [1090]. As of February 17, 2025, 13 cases are pending against Wella. Id. at 1. Wella’s motion [1090] is granted. Before the Court now are Wella’s motion to dismiss the complaint in its entirety. [757–762].4 II. Standard The Court assumes the parties’ familiarity with its explanation of the standards for Rule 12(b)(6) motions set forth in its first motion to dismiss opinion.

See [291] at 5. III. Analysis Wella moves to dismiss all of Plaintiffs’ claims. Defendants argue the Complaint is devoid of all factual allegations related to Wella and does not put Defendants on notice of the nature of the claims against them. [760] at 4; [762] at 4. Wella’s arguments fail and its motion to dismiss is denied. As an initial matter, Wella appears to misunderstand how to evaluate the

Master Complaint and the SFC. Neither document stands alone but together form one operative complaint. Thus, arguments that the SFC lacks allegations about how Plaintiffs’ use of Wella products caused injury or that the Master Complaint is devoid of allegations about which Wella products Plaintiffs used do not pass muster. See,

4 On July 18, 2024 the Court entered an order dismissing Plaintiff Davis’s case without prejudice, effective June 25, 2024. No. 1:23-cv-11227, [18]. Thus, Wella’s motion regarding Plaintiff Davis is denied as moot. [757, 758]. e.g., [760] at 4–5; [762] at 4–5. Wella must analyze the sufficiency of the allegations in the entire operative Complaint, which encompasses both the Master Complaint and the SFC. Wella’s motion suffers from another glaring error: rather than grapple

with the well-pleaded contentions set forth in the Complaint, Wella ignores all but 12 paragraphs of the 236 paragraph Master Complaint and 2 paragraphs in the SFC. [760] at 5; [762] at 5–6. All the allegations in the Master Complaint, even if they do not mention Wella by name, relate to Wella and its conduct. Focusing solely on the allegations that address Wella by name is improper. See Fernandes v. Rosalind Franklin Univ. of Med. & Sci., No. 19 CV 50337, 2021 WL 269879, at *3 (N.D. Ill.

Jan. 27, 2021) (“A motion to dismiss does not allow a defendant to simply ignore unfavorable allegations in the complaint.”). Wella asserts Plaintiffs only plead conclusory allegations and thus all 12 of Plaintiffs’ claims fail to plausibly state a claim. [753] at 15. The Court finds Defendants’ arguments undeveloped and unpersuasive. Wella does not address (much less differentiate between) the elements for each of the 12 causes of action. The Court will not develop the missing links in Defendants’ argument. See Stransky v.

Cummins Engine Co., Inc., 51 F.3d 1329, 1335 (7th Cir.1995) (noting that the “federal courts will not invent legal arguments for litigants”); Nilssen v. Gen. Electric, Co., 06 C 04155, 2011 WL 633414, at *9 (N.D. Ill. Feb. 11, 2011) (observing that in our adversarial system, “judges are not to supplant lawyers and perform their job of crafting and developing arguments”). The facts alleged in the Complaint are substantially the same as those the Court previously held were well-pleaded and provided fair notice of the same 12 claims Plaintiffs now bring against Wella. See [106, 291]. Plaintiffs allege Wella “manufactured, sold, distributed, advertised, and promoted toxic hair relaxer

products that caused Plaintiffs to develop cancers and other injuries.” [676] ¶ 1. The Master Complaint alleges Defendants “systematically misrepresented and continue to misrepresent the significant health impacts of hair relaxer use,” and failed to “disclos[e] the risks” or “warn[] women and children” about its “brutally toxic products,” “all while having knowledge that the hair relaxer products they designed, manufactured, advertised, and sold contained toxic carcinogens.” Id. ¶¶ 6–8.

According to Plaintiffs, Wella led “consumer[s] to believ[e] these hair relaxer products are safe when in fact they are not.” Id. ¶ 53. Plaintiffs explain that endocrine- disrupting chemicals (“EDCs”) are chemicals, or chemical mixtures, that interfere with the normal activity of the endocrine system. Id. ¶¶ 69–70.

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Related

Brewster McCauley v. City of Chicag
671 F.3d 611 (Seventh Circuit, 2011)
Brian Lax v. Alejandro Mayorkas
20 F.4th 1178 (Seventh Circuit, 2021)
Corwin v. Connecticut Valley Arms, Inc.
74 F. Supp. 3d 883 (N.D. Illinois, 2014)

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In RE: Hair Relaxer Marketing, Sales Practices, And Products Liability Litigation, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-hair-relaxer-marketing-sales-practices-and-products-liability-ilnd-2025.