Luckau v. Sunrun, Inc

CourtDistrict Court, N.D. California
DecidedJune 30, 2025
Docket4:25-cv-01661
StatusUnknown

This text of Luckau v. Sunrun, Inc (Luckau v. Sunrun, Inc) 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
Luckau v. Sunrun, Inc, (N.D. Cal. 2025).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 JEREMY LUCKAU, Case No. 25-cv-01661-JST

8 Plaintiff, ORDER REQUIRING SUPPLEMENTAL BRIEFING RE: 9 v. DEFENDANTS’ MOTION TO DISMISS; ORDER VACATING 10 SUNRUN INC., et al., HEARING 11 Defendants. Re: ECF No. 42

12 13 Before the Court is a motion to dismiss brought by Defendants Sunrun Inc. and Clean 14 Energy Experts, LLC (“CEE”). ECF No. 42. The Court has reviewed the parties’ written 15 arguments and, for the reasons discussed below, is inclined to find that Plaintiff Jeremy Luckau 16 lacks standing to pursue his second claim for relief, for violation of 47 C.F.R. § 64.1200(d)(4). 17 Luckau alleges that he registered his phone number on the National Do Not Call Registry 18 and that CEE, which is owned by Sunrun, made unsolicited calls to that number. ECF No. 29 19 ¶¶ 19–27, 55. Two voicemail messages said:

20 Hello this is Christine with Solar America responding to your request for information on solar energy for your home. We needed a 21 brief moment to verify the information that you submitted, and we’ll try to reach you again shortly or feel free to call us back at 1-800- 22 680-8554. Again, that number is 1-800-680-8554. We look forward to speaking with you. 23 24 Id. ¶ 24. Luckau contends that these messages violated 47 U.S.C. § 64.1200(d)(4), one of the 25 regulations promulgated under the Telephone Consumer Protection Act of 1991 (“TCPA”), 26 because the caller identified the entity as “Solar America,” instead of CEE. He also asserts, in his 27 first claim for relief that Defendants do not challenge in their motion to dismiss, that CEE 1 or an emergency purpose when leaving a voicemail with Luckau and members of the Prerecorded 2 Voice Class.” ECF No. 29 ¶ 98. He does not assert a claim under 47 C.F.R. § 64.1200(c)(2), 3 which prohibits calls to numbers on the National Do Not Call Registry. 4 Defendants argue that Luckau lacks Article III standing for his second claim because he 5 has not sufficiently alleged an injury, in part because, according to Defendants, Luckau’s wife 6 consented to the calls. However, “[u]nsolicited telemarketing phone calls or text messages, by 7 their nature, invade the privacy and disturb the solitude of their recipients,” and alleging receipt of 8 such calls or messages is sufficient to allege an injury in fact. Van Patten v. Vertical Fitness Grp., 9 LLC, 847 F.3d 1037, 1043 (9th Cir. 2017). In addition, “[e]xpress consent is not an element of a 10 plaintiff’s prima facie case but is an affirmative defense for which the defendant bears the burden 11 of proof.” Id. at 1044. Thus, as in Van Patten, a plaintiff may “allege[] a concrete injury in fact 12 sufficient to confer Article III standing” even if a court later concludes that the plaintiff 13 “consented to receiving the text messages” and “did not expressly revoke his consent.” Id. at 14 1043–44; see also Hall v. Smosh Dot Com, Inc., 72 F.4th 983, 990–91 (9th Cir. 2023) 15 (“Determining whether . . . consent was provided requires an analysis of the merits of [the 16 plaintiff’s] TCPA claim, and has no bearing on the question of Article III standing.” (citation 17 modified)). Luckau has sufficiently alleged a concrete injury, and whether his wife consented to 18 the calls goes to the merits of the case rather than to Article III standing. 19 But this does not end the Court’s standing inquiry. Standing also requires “a causal 20 connection between the injury and the conduct complained of.” Lujan v. Defs. of Wildlife, 504 21 U.S. 555, 560 (1992). In other words, the injury must be “fairly traceable to the challenged 22 conduct of the defendant.” Spokeo, Inc. v. Robins, 578 U.S. 330, 338 (2016). And “plaintiffs 23 must demonstrate standing for each claim that they press and for each form of relief that they 24 seek.” TransUnion LLC v. Ramirez, 594 U.S. 413, 431 (2021). The Court must therefore consider 25 whether Luckau’s alleged injury is fairly traceable to Defendants’ alleged violation of Section 26 64.1200(d)(4).1 27 1 Neither party considers that the requirement to identify “the name of the person or entity 2 on whose behalf the call is being made,” 47 C.F.R. § 64.1200(d)(4), is part of the TCPA’s 3 requirement to maintain an internal do-not-call list. Section 64.1200(d) provides, “No person or 4 entity shall initiate . . . any call for telemarketing purposes to a residential telephone subscriber 5 unless such person or entity has instituted procedures for maintaining a list of persons who request 6 not to receive such calls made by or on behalf of that person or entity.” 47 C.F.R. § 64.1200(d). 7 The identification requirement is one of the “minimum standards” that the instituted procedures 8 must satisfy. Id. 9 Luckau does not allege that he ever requested to be placed on Defendants’ internal do-not- 10 call list. He therefore appears to lack standing to assert a claim for violation of Section 11 64.1200(d)(4) because “even if Defendants had complied with the TCPA and maintained an 12 internal do-not-call list [that complied with all of the regulatory requirements], their compliance 13 would not have prevented a call to [Luckau] because he would not have been on that list.” 14 Perrong v. S. Bay Energy Corp., No. 2:20-cv-5781-JDW, 2021 WL 1387506, at *3 (E.D. Pa. 15 Apr. 13, 2021); see also Thompson v. Vintage Stock, Inc., No. 4:23-cv-00042-SRC, 2024 WL 16 492052, at *7 (E.D. Mo. Feb. 8, 2024), reconsideration granted on other grounds, 2024 WL 17 1636705 (E.D. Mo. Apr. 16, 2024) (finding no standing where the plaintiffs did not “allege in their 18 complaint that they asked Vintage Stock to place them on its internal do-not-call list, or even that 19 they asked Vintage Stock not to contact them” because, “even if Vintage Stock had done 20 everything the Thompsons complain it failed to do,” the plaintiffs “would have suffered the exact 21 same harm”); Doane v. Benefytt Techs., Inc., Civ. Action No. 22-10510-FDS, 2023 WL 2465628, 22 at *7 (D. Mass. Mar. 10, 2023) (finding no standing where the plaintiff alleged he asked to be 23 placed on an internal do-not-call list but failed to allege that he received any calls from the 24 defendant after that date). 25 Some courts have held to the contrary and concluded that a plaintiff has standing to assert 26 violations of Section 64.1200(d)(4) even if they did not request to be placed on an internal do-not- 27 1 call list. One court reasoned that it would not “make sense” to require “that a stop request . . . be 2 made before a violation of subsection (d) can be found” because “forcing sellers to identify 3 themselves ensures that a subscriber has the information needed to make a stop request.” Dawson 4 v. Porch.com, No. 2:20-cv-00604-RSL, 2024 WL 4765159, at *8 (W.D. Wash. Nov. 13, 2024). 5 Another court similarly noted:

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Related

Summers v. Earth Island Institute
555 U.S. 488 (Supreme Court, 2009)
Spokeo, Inc. v. Robins
578 U.S. 330 (Supreme Court, 2016)
Bradley Van Patten v. Vertical Fitness Group
847 F.3d 1037 (Ninth Circuit, 2017)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)
Kristen Hall v. Smosh Dot Com, Inc.
72 F.4th 983 (Ninth Circuit, 2023)

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Luckau v. Sunrun, Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/luckau-v-sunrun-inc-cand-2025.