Johnson-Jack v. Health-Ade LLC

CourtDistrict Court, N.D. California
DecidedFebruary 24, 2022
Docket3:21-cv-07895
StatusUnknown

This text of Johnson-Jack v. Health-Ade LLC (Johnson-Jack v. Health-Ade LLC) 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
Johnson-Jack v. Health-Ade LLC, (N.D. Cal. 2022).

Opinion

1 2 3 4 5 6 7 8 UNITED STATES DISTRICT COURT 9 NORTHERN DISTRICT OF CALIFORNIA 10 San Francisco Division 11 BRANDON JOHNSON-JACK, et al., Case No. 21-cv-07895-LB

12 Plaintiffs, ORDER DENYING MOTION TO 13 v. DISMISS

14 HEALTH-ADE LLC, Re: ECF No. 18 15 Defendant. 16 17 INTRODUCTION 18 In this consumer-products mislabeling class action, the plaintiffs allege that the defendant’s 19 use of the term “Health-Ade” to market kombucha-inspired beverages, including Health-Ade 20 Kombucha, Health-Ade Plus, Health-Ade Booch Pop, Health-Ade pop, and Health-Ade Mixers, 21 violates California law. The plaintiffs’ theory is that the term “Health-Ade” is misleading because 22 it implies that the defendant’s products are healthy when, according to the plaintiffs, they are not 23 because they contain sugar.1 Most courts in this district have found that mislabeling claims based 24 on this theory (i.e., that it is deceptive to market products with added sugar as healthy based on 25 studies linking excess sugar consumption to disease) can survive a motion to dismiss and that the 26 27 1 Compl. – ECF No. 1 at 2 (¶ 1). Citations refer to material in the Electronic Case File (ECF); pinpoint 1 term “healthy” is not puffery. The Ninth Circuit has not yet issued a controlling decision. Thus, 2 the court denies the defendant’s motion to dismiss.2 3 4 ANALYSIS 5 The named plaintiffs allege that they regularly purchased Health-Ade Kombucha during the 6 class period.3 According to the complaint, the product’s label is misleading because it implies that 7 the drinks are healthy when the “high sugar content” makes the drinks unhealthy.4 The plaintiffs 8 assert claims for relief under the (1) California Business and Professions Code §§ 17200, et seq., 9 (i.e., Unfair Competition Law or UCL) for unfair business practices, (2) California Business and 10 Professions Code §§ 17500, et seq., (i.e., False Advertising Law or FAL) for deceptive 11 advertising, and (3) California Civil Code §§ 1750, et seq., (i.e., Consumer Legal Remedies Act or 12 CLRA) for deceptive practices.5 They also assert claims for breach of implied and express 13 warranties.6 14 The defendant, Health-Ade LLC, asks the court to dismiss the complaint for several reasons. 15 Its main argument is that the term “Health-Ade” is not misleading because the amount of sugar in 16 the products is accurately disclosed in the nutrition facts box and ingredients list on the label.7 The 17 defendant also contends that the term “health” is non-actionable puffery and that federal laws 18 concerning food labeling preempt the plaintiffs’ claims.8 Finally, the defendant contends that the 19 plaintiffs do not (1) satisfy the heightened pleading standards under Federal Rule of Civil 20 21 22

23 2 The court held a hearing on the defendant’s motion on January 20, 2022. All parties consented to magistrate-judge jurisdiction. Consents – ECF Nos. 8, 20. 24 3 Compl. – ECF No. 1 at 27 (¶¶ 84–85). 25 4 Id. at 27 (¶ 86). 26 5 Id. at 31–35 (¶¶ 111–143). 6 Id. at 35–36 (¶¶ 144–155). 27 7 Mot. – ECF No. 18 at 10, 13–14. 1 Procedure 9(b), (2) have grounds to seek injunctive relief because they have an adequate remedy 2 at law, or (3) have standing to assert claims based on products they did not purchase.9 3 The term “Health-Ade” implies to reasonable consumers that the defendant’s products are 4 healthy, and the plaintiffs have plausibly alleged that the products are unhealthy by citing scientific 5 studies that allegedly link the consumption of sugar-sweetened beverages to negative health 6 outcomes. Whether the defendant’s products are, in fact, healthy or unhealthy cannot be resolved at 7 this stage. While the term “healthy” can be difficult to define, many courts in this district have held 8 that it is not puffery because consumers rely on it when purchasing food products. Federal law does 9 not preempt the plaintiffs’ claims because the challenged term is not a “health” claim or “nutrient 10 content” claim, which are the relevant types of labeling statements governed by federal law. 11 Furthermore, the plaintiffs have adequately pled “the who, what, when, where, and how” of 12 the alleged fraud for purposes of Rule 9(b) by describing the element of the label that is allegedly 13 misleading, pleading the time of the alleged fraud by reference to the class period, and supporting 14 their claim that sugar-sweetened beverages are unhealthy based on scientific studies. The plaintiffs 15 have standing to seek injunctive relief because the difficult-to-ascertain nature of the alleged 16 misrepresentation suggests that the plaintiffs will not be able to rely on the labeling statements in 17 the future. Thus, the court denies the motion to dismiss. 18 19 1. Applicable Legal Standard 20 A complaint must contain “a short and plain statement of the claim showing that the pleader is 21 entitled to relief” to give the defendant “fair notice” of what the claims are and the grounds upon 22 which they rest. Fed. R. Civ. P. 8(a)(2); Bell Atl. Corp. v. Twombly, 550 U.S. 544, 555 (2007) 23 (cleaned up). A complaint does not need detailed factual allegations, but “a plaintiff’s obligation to 24 provide the ‘grounds’ of his ‘entitlement to relief’ requires more than labels and conclusions, and a 25 formulaic recitation of the elements of a cause of action will not do. Factual allegations must be 26 27 1 enough to raise a right to relief above the speculative level[.]” Twombly, 550 U.S. at 555 (cleaned 2 up). 3 To survive a motion to dismiss, a complaint must contain sufficient factual allegations, which 4 when accepted as true, “‘state a claim to relief that is plausible on its face.’” Ashcroft v. Iqbal, 556 5 U.S. 662, 678 (2009) (quoting Twombly, 550 U.S. at 570). “A claim has facial plausibility when 6 the plaintiff pleads factual content that allows the court to draw the reasonable inference that the 7 defendant is liable for the misconduct alleged.” Id. (citing Twombly, 550 U.S. at 556). “The 8 plausibility standard is not akin to a ‘probability requirement,’ but it asks for more than a sheer 9 possibility that a defendant has acted unlawfully.” Id. (quoting Twombly, 550 U.S. at 556). 10 “Where a complaint pleads facts that are merely consistent with a defendant’s liability, it stops 11 short of the line between possibility and plausibility of ‘entitlement to relief.’” Id. (cleaned up) 12 (quoting Twombly, 550 U.S. at 557). 13 If a court dismisses a complaint, it should give leave to amend unless the “pleading could not 14 possibly be cured by the allegation of other facts.” United States v. United Healthcare Ins. Co., 15 848 F.3d 1161, 1182 (9th Cir. 2016) (cleaned up). 16 17 2. Unfair Competition Statutory Claims – Reasonable Consumer Test 18 Claims under the CLRA, FAL, and UCL are governed by the “reasonable consumer” test. 19 Williams v. Gerber Prods. Co., 552 F.3d 934, 938 (9th Cir. 2008). Given that the same standard 20 applies, courts often analyze claims under these statutes together. Hadley v. Kellogg Sales Co., 21 273 F. Supp. 3d 1052, 1063 (N.D. Cal. 2017) (“Hadley I”). “Under the reasonable consumer 22 standard, [plaintiffs] must show that ‘members of the public are likely to be deceived.’” Williams, 23 552 F.3d at 938 (cleaned up). 24 Generally, determining “whether a reasonable consumer would be deceived” is a question of 25 fact. Cheslow v. Ghirardelli Chocolate Co., 445 F. Supp. 3d 8, 16 (N.D. Cal. 2020); see also Reid 26 v.

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Johnson-Jack v. Health-Ade LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/johnson-jack-v-health-ade-llc-cand-2022.