Matthew Schmitt v. Newell Brands Inc

CourtCourt of Appeals for the Third Circuit
DecidedJanuary 9, 2025
Docket23-1738
StatusUnpublished

This text of Matthew Schmitt v. Newell Brands Inc (Matthew Schmitt v. Newell Brands Inc) 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
Matthew Schmitt v. Newell Brands Inc, (3d Cir. 2025).

Opinion

NOT PRECEDENTIAL

UNITED STATES COURT OF APPEALS FOR THE THIRD CIRCUIT _____________

No. 23-1738 _____________

MATTHEW SCHMITT, Individually and on behalf of all others similarly situated, Appellant

v.

NEWELL BRANDS INC.; GRACO CHILDRENS PRODUCTS, INC. _______________

On Appeal from the United States District Court for the District of New Jersey (D.C. No. 3:20-cv-16240) District Judge: Honorable Zahid N. Quraishi _______________

Submitted Pursuant to Third Circuit L.A.R. 34.1(a) October 1, 2024

Before: SHWARTZ, MATEY, and SCIRICA, Circuit Judges

(Filed: January 9, 2025) _______________

OPINION _______________

 This disposition is not an opinion of the full Court and, under I.O.P. 5.7, does not constitute binding precedent. MATEY, Circuit Judge.

Matthew Schmitt bought a car seat manufactured by Newell and Graco, intending

to use the seat for the entire decade of its warranty life. When Schmitt realized that the

car seat would require a replacement before the end of its warranty life, he sued for

money damages and injunctive relief. The District Court granted the Defendants’ motion

to dismiss and, finding no error, we will affirm.

I.

In August 2020, Schmitt bought a “SlimFitTM Platinum 3-in-1 Car Seat”

manufactured by the Defendants, “intending to use it for ten years, not only for his

current child, but with hopes of utilizing it for future children as well.” App. 31. The

accompanying manual instructs consumers to “STOP using this car seat and throw it

away 10 years after the date of manufacture,” a warning reiterated on Graco’s website,

advising that “[c]ar seats can be used safely only for a defined period of time, typically 7

to 10 years.” App. 31 (alteration in original). Graco advertises that a different product, the

“4Ever All-in-1 Convertible Car Seat,” will “giv[e] you 10 years with one car seat.” App.

31. But that is not the car seat Schmitt purchased.

When Schmitt received his purchase, it was affixed with a sticker indicating that it

was manufactured in March 2019. Schmitt claims the gap between manufacture and sale

cut some 15% from the value because it deprived him from using the car seat for the

entire ten-years he anticipated. Displeased, Schmitt filed a putative class action lawsuit

against the Defendants, alleging violations of the New Jersey Consumer Fraud Act, N.J.

2 Stat. Ann. § 56:8-1 et seq., negligent misrepresentation, fraud, and unjust enrichment,

seeking monetary damages and injunctive relief. The District Court granted the

Defendants’ motion to dismiss, holding that Schmitt lacked standing to seek monetary

damages or injunctive relief. Schmitt now appeals.1

II.

A.

Our analysis begins, and ends, with standing, the requirement that a plaintiff “must

show that []he has suffered, or will suffer, an injury that is ‘concrete, particularized, and

actual or imminent; fairly traceable to the challenged action; and redressable by a

favorable ruling.’” Murthy v. Missouri, 603 U.S. 43, 57 (2024) (quoting Clapper v.

Amnesty Int’l USA, 568 U.S. 398, 409 (2013)). This “injury must be actual or imminent,

not speculative.” Food & Drug Admin. v. All. for Hippocratic Med., 602 U.S. 367, 381

(2024).

Schmitt’s alleged injury stems from the reduced value of the car seat due to his

inability to use the car seat for his “current child” and any “future children” during the

full ten year-period after his purchase.2 App. 31. Because of the delay between the

1 The District Court had jurisdiction under 28 U.S.C. § 1332. We have jurisdiction under 28 U.S.C. § 1291. We review de novo an order granting a motion to dismiss, Borough of Longport v. Netflix, Inc., 94 F.4th 303, 306 (3d Cir. 2024) and “may affirm on any ground supported by the record,” Beasley v. Howard, 14 F.4th 226, 231 (3d Cir. 2021). “[W]e accept as true the factual allegations in the complaint, and draw all reasonable inferences in the plaintiff’s favor.” Host Int’l, Inc. v. MarketPlace, PHL, LLC, 32 F.4th 242, 248 (3d Cir. 2022) (quoting Phila. Taxi Ass’n, Inc. v. Uber Techs., Inc., 886 F.3d 332, 338 (3d Cir. 2018)). 2 Schmitt does not allege that the car seat presently suffers from a defect. 3 manufacture date and Schmitt’s date of purchase, Schmitt’s car seat will expire in March

2029, rather than August 2030. On this ten-year timeline, Schmitt’s need for the car seat

past the end of this decade will not “be likely to occur soon.” All. for Hippocratic Med.,

602 U.S. at 381 (citing Clapper, 568 U.S. at 409); see also Thorne v. Pep Boys Manny

Moe & Jack Inc., 980 F.3d 879, 887 (3d Cir. 2020) (explaining that “uncertain future

events do not make [a product] worth less at the time of purchase”). Nor has Schmitt

shown that his future need for the car seat is “certainly impending,” Clemens v.

ExecuPharm Inc., 48 F.4th 146, 152 (3d Cir. 2022) (quoting Susan B. Anthony List v.

Driehaus, 573 U.S. 149, 158 (2014)), because his daughter will have outgrown the seat

by 2029, and Schmitt does not currently have any other children. As Schmitt cannot

demonstrate an actual or imminent injury, he lacks standing to pursue monetary

damages.3

B.

Nor can Schmitt sustain his claim for injunctive relief. Since “standing is not

dispensed in gross,” Schmitt “must demonstrate standing . . . for each form of relief that

[he] seek[s].” Murthy, 603 U.S. at 61 (quoting TransUnion LLC v. Ramirez, 594 U.S.

413, 431 (2021)). “[A] party seeking prospective relief ‘must allege facts from which it

appears there is a substantial likelihood that he will suffer injury in the future.’” Durham

3 Having determined that Schmitt’s standing is foreclosed by his lack of an actual or imminent injury, we decline to consider whether his claims could proceed absent a contract. 4 v. Kelley, 82 F.4th 217, 226 (3d Cir. 2023) (quoting Bauer v. Texas, 341 F.3d 352, 358

(5th Cir. 2003)).

Schmitt sought injunctive relief because he “would like to be able to purchase a

Graco Car Seat in the future, but would like to be able to know what the useful life of the

product he is purchasing is.” App. 35. He has since clarified that he would not suffer any

“future injury.” Opening Br. at 11 n.1. Absent a future injury, Schmitt does not have

standing to seek injunctive relief.

****

The District Court did not err in granting the Defendants’ motion to dismiss. So

we will affirm.

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Related

Clapper v. Amnesty International USA
133 S. Ct. 1138 (Supreme Court, 2013)
Vickie Thorne v. Pep Boys Manny Moe & Jack
980 F.3d 879 (Third Circuit, 2020)
TransUnion LLC v. Ramirez
594 U.S. 413 (Supreme Court, 2021)
David Beasley v. William Howard
14 F.4th 226 (Third Circuit, 2021)
Host International Inc v. MarketPlace PHL LLC
32 F.4th 242 (Third Circuit, 2022)
Tharp v. United States Fidelity & Guaranty Co.
2 Ohio App. 28 (Ohio Court of Appeals, 1913)
Jennifer Clemens v. Execupharm Inc
48 F.4th 146 (Third Circuit, 2022)
Tremayne Durham v. G. Kelley
82 F.4th 217 (Third Circuit, 2023)
Borough of Longport v. Netflix Inc
94 F.4th 303 (Third Circuit, 2024)
Murthy v. Missouri
603 U.S. 43 (Supreme Court, 2024)

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Bluebook (online)
Matthew Schmitt v. Newell Brands Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/matthew-schmitt-v-newell-brands-inc-ca3-2025.