Leda Health Corporation v. Inslee

CourtDistrict Court, W.D. Washington
DecidedJanuary 3, 2025
Docket2:24-cv-00871
StatusUnknown

This text of Leda Health Corporation v. Inslee (Leda Health Corporation v. Inslee) 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
Leda Health Corporation v. Inslee, (W.D. Wash. 2025).

Opinion

1 2 3 4 5

6 7 UNITED STATES DISTRICT COURT 8 WESTERN DISTRICT OF WASHINGTON AT TACOMA 9 10 LEDA HEALTH CORPORATION, CASE NO. 2:24-cv-00871-DGE 11 Plaintiff, ORDER ON MOTION FOR 12 v. INJUNCTION PENDING APPEAL (DKT. NO. 46) 13 JAY ROBERT INSLEE et al., 14 Defendant. 15

16 I INTRODUCTION 17 This matter comes before the Court on Plaintiff Leda Health Corporation’s motion for 18 injunction pending appeal. (Dkt. No. 46.) Defendant filed a response (Dkt. No. 51), to which 19 Plaintiff replied (Dkt. No. 52). For the foregoing reasons, the Court DENIES Plaintiff’s motion. 20 II BACKGROUND 21 On October 21, 2024, the Court denied Plaintiff’s motion for a preliminary injunction and 22 granted Defendant’s motion to dismiss. (Dkt. No. 42.) The factual and procedural background 23 24 1 of this matter is set forth in detail in the Court’s recent order. (See id.) Accordingly, only a brief 2 account of the relevant facts is provided herein. 3 Leda Health is a company known for developing Early Evidence Kits (“EEKs”)— 4 products that allegedly enable sexual assault survivors to “self-collect and store evidence such as 5 DNA” if they are unable or unwilling to seek a traditional forensic medical examination. (Dkt.

6 No. 11 at 4.) On October 31, 2022, the Washington State Attorney General’s Office (AGO) 7 issued Leda a notification directing the company to “immediately cease and desist from 8 advertising, marketing, and sales to Washington consumers related to its ‘Early Evidence Kits’ 9 on the basis that Leda’s business practices related to these kits violated the Washington 10 Consumer Protection Act.” (Dkt. No 19-1 at 29.) The letter stated that “Leda’s claims regarding 11 the admissibility of its at-home kits have the capacity to deceive a Washington consumer into 12 believing that its Early Evidence Kits have equivalent evidentiary value to a sexual assault 13 evidence kit (“SAEK”) administered by a medical professional.” (Id. at 30). The notice went on 14 to assert that the self-administered nature of Leda’s EEKs would predictably result in “numerous

15 barriers to admission as evidence, including on the basis of potential cross-contamination, 16 spoilation, and validity.” (Id.) It emphasized that, in Washington, exams by a trained Sexual 17 Assault Nurse Examiner (SANE) are “both free and routinely admissible.” (Id. at 31.) Thus, the 18 letter concluded that “Leda charging consumers for Early Evidence Kits despite the fact they are 19 unlikely to be admissible in a criminal court is an unfair and deceptive business practice” in 20 violation of the Washington Consumer Protection Act. (Id.) 21 Subsequently, Washington’s legislature passed House Bill 1564, “An Act Relating to 22 prohibiting the sale of over-the-counter sexual assault kits.” (Dkt. No. 19-1 at 3.) The law went 23 into effect on July 23, 2023. (Dkt. No. 30 at 13.) Several representatives from Leda Health 24 1 testified at hearings on the bill, asserting that Leda’s kits are not misleading but rather intended 2 to be an additive option for the approximately 70% of sexual assault victims who do not go to the 3 hospital, or for those who go but are not able to see a SANE nurse. (Dkt. No. 13 at 181.) Leda 4 further stated that while the company did not guarantee evidence admissibility, it had procedures 5 in place to establish chain of custody and believed that evidence from its kits should be

6 admissible in court. (Id.) Thus, it concluded “[t]he sale of over-the-counter sexual assault kits 7 may prevent survivors from receiving accurate information about their options and reporting 8 processes; from obtaining access to appropriate and timely medical treatment and follow up; and 9 from connecting to their community and other vital resources.” Id. 10 Entitled “[o]ver-the-counter sexual assault kits” and codified at Washington Revised 11 Code § 5.70.070, the act establishes that: 12 (2) A person may not sell, offer for sale, or otherwise make available a sexual assault kit:

13 a) That is marketed or otherwise presented as over-the-counter, at-home, or self-collected or in any manner that indicates that the sexual assault kit may 14 be used for the collection of evidence of sexual assault other than by law enforcement or a health care provider; or 15 b) If the person intends, knows, or reasonably should know that the sexual 16 assault kit will be used for the collection of evidence of sexual assault other than by law enforcement or a health care provider. 17 Wash. Rev. Code § 5.70.070(2). The statute defines “sexual assault kit” as “a product with 18 which evidence of sexual assault is collected.” Wash. Rev. Code § 5.70.070(1). It further 19 stipulates that a violation of the section constitutes “an unfair or deceptive act in trade or 20 commerce and an unfair method of competition for the purpose of applying [Washington’s] 21 consumer protection act.” Wash. Rev. Code § 5.70.070(3). 22 On June 17, 2024, Plaintiff filed a Complaint for declaratory and injunctive relief, 23 asserting that Washington Revised Code § 5.70.070 (hereinafter “the Statute”) was 24 1 unconstitutional on multiple counts in violation of 42 U.S.C. § 1983. (Dkt. No. 1.) The 2 Complaint claimed that the Statute impermissibly regulated protected speech in violation of the 3 First and Fourteenth Amendments and was thus unconstitutional facially and as applied to Leda 4 Health. (Id. at 13–16.) The complaint further alleged that the Statute was void for overbreadth 5 and vagueness, both facially and as applied, and that it constituted an unconstitutional bill of

6 attainder. (Id. at 16–20.) Plaintiff moved for a preliminary injunction to prevent enforcement of 7 the Statute (Dkt. No. 10) and Defendant filed a motion to dismiss (Dkt. No. 30). The Court 8 found that the merits of Plaintiff’s claims failed as a matter of law; accordingly, the Court denied 9 Plaintiff’s motion for a preliminary injunction and granted Defendant’s motion to dismiss. (Dkt. 10 No. 42.) 11 Plaintiff subsequently filed the instant motion for injunction pending appeal, arguing that 12 the “[t]he Court erred” in finding that Leda failed to put forth a cognizable facial First 13 Amendment claim. (Dkt. No. 46 at 3.) Because the Statute violates Leda’s First Amendment 14 rights, Leda asserts, the company is entitled to an injunction pending appeal. (Id.) Leda does not

15 address the other constitutional arguments it raised in its original motion for preliminary 16 injunction—thus, the motion at hand is based entirely upon its facial First Amendment challenge 17 to the Statute. (Id.) Defendant argues that “Leda presents no new arguments justifying an 18 injunction pending appeal” and thus “Leda is still not likely to succeed on the merits of its free 19 speech claims.” (Dkt. No. 51 at 5.) 20 III LEGAL STANDARD 21 Pursuant to Federal Rule of Civil Procedure 62(d), the Court may grant an injunction on 22 terms . . . that secure the opposing party’s rights” pending appeal of “an interlocutory order or 23 final judgment that grants, continues, modifies, refuses, dissolves, or refuses to dissolve or 24 1 modify an injunction.” “The standard for evaluating an injunction pending appeal is similar to 2 that employed . . . in deciding whether to grant a preliminary injunction.” Feldman v. Ariz. Sec. 3 of State's Office, 843 F.3d 366, 367 (9th Cir. 2016).

Free access — add to your briefcase to read the full text and ask questions with AI

Related

United States v. Smith
532 F.3d 1125 (Eleventh Circuit, 2008)
Friedman v. Rogers
440 U.S. 1 (Supreme Court, 1979)
Standefer v. United States
447 U.S. 10 (Supreme Court, 1980)
Bolger v. Youngs Drug Products Corp.
463 U.S. 60 (Supreme Court, 1983)
Board of Trustees of State Univ. of NY v. Fox
492 U.S. 469 (Supreme Court, 1989)
Edenfield v. Fane
507 U.S. 761 (Supreme Court, 1993)
United States v. Morrison
529 U.S. 598 (Supreme Court, 2000)
Lorillard Tobacco Co. v. Reilly
533 U.S. 525 (Supreme Court, 2001)
Whitaker, Julian v. Thompson, Tommy
353 F.3d 947 (D.C. Circuit, 2004)
Leiva-Perez v. Holder
640 F.3d 962 (Ninth Circuit, 2011)
L C & S, Inc. v. Warren County Area Plan Commission
244 F.3d 601 (Seventh Circuit, 2001)
Clear Channel Outdoor, Inc. v. City of New York
594 F.3d 94 (Second Circuit, 2010)
Pom Wonderful, LLC v. Federal Trade Commission
777 F.3d 478 (D.C. Circuit, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
Leda Health Corporation v. Inslee, Counsel Stack Legal Research, https://law.counselstack.com/opinion/leda-health-corporation-v-inslee-wawd-2025.