Marie Lamb v. CVS Pharmacy LLC

CourtCourt of Appeals for the Third Circuit
DecidedJune 13, 2025
Docket24-1709
StatusUnpublished

This text of Marie Lamb v. CVS Pharmacy LLC (Marie Lamb v. CVS Pharmacy LLC) is published on Counsel Stack Legal Research, covering Court of Appeals for the Third Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Marie Lamb v. CVS Pharmacy LLC, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT

No. 24-1709

MARIE G. LAMB, Appellant v. CVS PHARMACY LLC

Appeal from the United States District Court for the Eastern District of Pennsylvania (District Court No. 2:21-cv-00638) District Judge: Honorable Paul S. Diamond

Submitted under Third Circuit L.A.R. 34.1(a) March 28, 2025 Before: BIBAS, PHIPPS, and AMBRO, Circuit Judges (Opinion filed June 13, 2025)

OPINION*

AMBRO, Circuit Judge

In December 2019, Marie Lamb’s son, Thomas Austin, brought 16 VHS tapes

containing family memories to a CVS Pharmacy in Philadelphia to be converted into

* This disposition is not an opinion of the full Court and pursuant to I.O.P. 5.7 does not constitute binding precedent. DVDs. When he gave the tapes to CVS, he received 16 receipts. Each contained the

following limitation-of-liability language:

READ THIS NOTICE: the submission of film, prints, slides, negatives, videos, CD or any other media for processing, printing, or any other handling, constitutes an agreement by you that if such film, slides, negatives, videos, CD or any other media is damaged, lost or mishandled by FUJIFILM North America Corporation, its affiliates, retailers, agents or employees, even though due to the negligence or other fault of any of the foregoing, liability will be limited to replacement of an equivalent amount of unexposed film or media and processing. The forgoing [sic] will be your exclusive remedy for any such loss, damage or mishandling. Except for such replacement the acceptance for processing, printing, or handling of any film, slides, negatives, videos, CD or any other media is without warranty whatsoever (whether expressed or implied) or other liability of any kind. Recovery for incidental, punitive, indirect or consequential damages is specifically waived and excluded. NOT RESPONSIBLE FOR PROPERTY LEFT OVER 30 DAYS.

App. 87-102.

CVS sent the tapes to Fujifilm through the U.S. Postal Service, and the tapes were

lost. CVS inquired with USPS about the tapes to no avail. Lamb and Austin also asked

various CVS personnel about the tapes, but no one could locate them.

I

In 2020, Lamb sued CVS in the Court of Common Pleas of Philadelphia County.

She sought the return of her tapes, information about CVS’s investigation, and punitive

and compensatory damages. CVS removed the matter to the United States District Court

for the Eastern District of Pennsylvania.

This action stems from Lamb’s second amended complaint in that Court, alleging

violations of Pennsylvania law. She claimed (1) the right to replevin the tapes, (2) breach

of contract, (3) negligent infliction of emotional distress (NIED), and (4) fraud. In 2022,

2 the District Court dismissed her claims for NIED and fraud with prejudice, thereby denying

her request for punitive damages.

In 2023, CVS moved for partial summary judgment on Lamb’s remaining claims of

replevin and breach of contract. It argued Lamb’s claim for replevin should be dismissed

as moot. Though conceding breach of contract, CVS asserted that damages, under the

limitation-of-liability provision, should not exceed the approximate cost of replacing the

tapes—$334.84.1 The Court granted CVS’s motion and awarded Lamb that amount. She

does not dispute the dismissal of her NIED and fraud claims nor the grant of summary

judgment on her replevin claim. She timely appealed, however, the District Court’s

enforcement of the limitation-of-liability provision.2 We agree with the District Court and

thus affirm.

II

The District Court had jurisdiction under 28 U.S.C. §§ 1332 and 1441. We have

jurisdiction under 28 U.S.C. § 1291. “We review the District Court’s grant of summary

judgment de novo.” Lichtenstein v. Univ. of Pittsburgh Med. Ctr., 691 F.3d 294, 300 (3d

Cir. 2012).

1 CVS calculated this amount by adding the price of converting the first VHS tape ($25.99), each subsequent tape ($9.99 each), and 16 blank VHS tapes ($10 each). 2 Lamb also attempts to revive a negligence claim she brought in her initial complaint. The operative complaint, however, is the Second Amended Complaint, and we do not consider allegations from the initial complaint. Garrett v. Wexford Health, 938 F.3d 69, 82 (3d Cir. 2019) (“In general, an amended pleading supersedes the original pleading and renders the original pleading a nullity. Thus, the most recently filed amended complaint becomes the operative pleading.” (internal citations omitted)).

3 Lamb argues that the liability limitation is unenforceable because it is exculpatory,

arises in the consumer context, lacks conspicuousness, is unconscionable, and offers an

inadequate remedy. She also contends that the contract is ambiguous and does not apply to

CVS because the provision pertains to Fujifilm and the tapes were intended to be sent to a

different third-party vendor, “yesvideo.”

First, the provision is not exculpatory. In Pennsylvania, courts recognize a

distinction between an exculpatory contract—one that completely absolves a party of

liability—and a contract that simply limits the extent of liability. Posttape Assocs. v.

Eastman Kodak Co., 537 F.2d 751, 755 (3d Cir. 1976); Valhal Corp. v. Sullivan Assocs.,

44 F.3d 195, 202 (3d Cir. 1995). Here, the provision states that “liability will be limited to

replacement of an equivalent amount of unexposed film or media and processing.”

App. 87–102. That clause only limits damages—it does not absolve CVS from liability.

Second, we reject Lamb’s argument that the liability limitation is unenforceable

because she and Austin are unsophisticated parties who did not read that provision. Lamb

repeatedly relies on Valhal Corp., 44 F.3d at 203–04, to argue that the limitation-of-liability

provision is unenforceable because she and her son are ordinary consumers and not

business entities. This argument fails. In Valhal, we recognized that limitation-of-liability

provisions are enforceable outside the commercial context. Id. at 203. And courts have

enforced those limitations under Pennsylvania law against ordinary consumers in a variety

of contexts, including gym membership agreements and cruise tickets. See Hinkal v.

Pardoe, 133 A.3d 738, 743 (Pa. Super. Ct. 2016) (en banc); Marek v. Marpan Two, Inc.,

817 F.2d 242, 245–47 (3d Cir. 1987). In addition, “failure to read [the] agreement does not

4 render it either invalid or unenforceable.” Hinkal, 133 A.3d at 743.

Third, Lamb’s argument that the provision is inconspicuous also fails. A provision

is “conspicuous when it is so written that a reasonable person against whom it is to operate

ought to have noticed it.” Moscatiello v.

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Related

Posttape Associates v. Eastman Kodak Company
537 F.2d 751 (Third Circuit, 1976)
Lobianco v. Property Protection, Inc.
437 A.2d 417 (Superior Court of Pennsylvania, 1981)
Moscatiello v. Pittsburgh Contractors Equipment Co.
595 A.2d 1190 (Superior Court of Pennsylvania, 1991)
Hinkal, M. v. Pardoe, G.
133 A.3d 738 (Superior Court of Pennsylvania, 2016)
Kareem Garrett v. Wexford Health
938 F.3d 69 (Third Circuit, 2019)
Borden, Inc. v. Advent Ink Co.
701 A.2d 255 (Superior Court of Pennsylvania, 1997)
Emerman v. Baldwin
142 A.2d 440 (Superior Court of Pennsylvania, 1958)

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Bluebook (online)
Marie Lamb v. CVS Pharmacy LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/marie-lamb-v-cvs-pharmacy-llc-ca3-2025.