Miguel Rodriguez v. Just Brands USA, Inc.

CourtDistrict Court, C.D. California
DecidedMay 18, 2021
Docket2:20-cv-04829
StatusUnknown

This text of Miguel Rodriguez v. Just Brands USA, Inc. (Miguel Rodriguez v. Just Brands USA, Inc.) is published on Counsel Stack Legal Research, covering District Court, C.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Miguel Rodriguez v. Just Brands USA, Inc., (C.D. Cal. 2021).

Opinion

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8 United States District Court 9 Central District of California

11 MIGUEL RODRIGUEZ, on behalf of Case № 2:20-CV-04829-ODW (PLAx) himself and others similarly situated, 12 Plaintiff, ORDER DENYING MOTION TO 13 v. STAY [65], AND GRANTING 14 MOTION TO DISMISS [63] JUST BRANDS USA, INC., JUST 15 BRANDS, INC., and SSGI FINANCIAL SERVICES, INC., 16 Defendants. 17 18 I. INTRODUCTION 19 Plaintiff Miguel Rodriguez filed this putative class action against Defendants 20 Just Brands USA, Inc., Just Brands, Inc., and SSGI Financial Services, Inc. (First Am. 21 Compl. (“FAC”), ECF No. 60.) Defendants now move to (1) stay the case pending 22 regulatory guidance from the Food and Drug Administration (“FDA”), and 23 (2) alternatively, to dismiss the FAC. (Mot. Stay (“MTS”), ECF No. 65; Mot. Dismiss 24 (“MTD”), ECF No. 63; see also Opp’n MTS, ECF No. 68; Reply ISO MTS, ECF 25 No. 70; Opp’n MTD, ECF No. 67; Reply ISO MTD, ECF No. 69.) For the following 26 reasons, the Motion to Stay is DENIED, and the Motion to Dismiss is GRANTED.1 27

28 1 After carefully considering the papers filed in connection with the Motions, the Court deemed the matters appropriate for decision without oral argument. Fed. R. Civ. P. 78; C.D. Cal. L.R. 7-15. 1 II. BACKGROUND 2 Defendants sell cannabidiol (“CBD”) products under the brand “JustCBD,” 3 which includes CBD-infused “compounds, tinctures, and edibles.” (FAC ¶¶ 1, 7–10.) 4 On October 2, 2018, and March 17, 2019, Plaintiff purchased JustCBD vape 5 cartridges, gummies, and dog treats after reviewing and relying on the “product 6 packaging, which promised specific quantities of CBD.” (Id. ¶¶ 5–6.) Plaintiff claims 7 that he later discovered, through independent lab testing commissioned by counsel, 8 that JustCBD products contained between 10% to 100% less CBD content than 9 promised on its labels. (Id. ¶ 20.) Accordingly, Plaintiff complains that he “paid a 10 substantial premium due to the false and misleading CBD claims . . . [and] did not 11 receive the benefit of his bargain. (Id. ¶ 6.) 12 Plaintiff commenced this putative class action on May 29, 2020, against 13 Defendants collectively as the manufacturers, distributors, and sellers of JustCBD 14 products, each responsible for its “advertising, marketing, and packaging.” (Id. 15 ¶¶ 7–9.) Plaintiff asserts seven causes of action against Defendants for: (1) breach of 16 express warranty; (2) unjust enrichment; (3) fraud; (4) violation of the California 17 Consumers Legal Remedies Act (“CLRA”), California Civil Code sections 1750, et 18 seq.; (5) violation of California’s Unfair Competition Law (“UCL”), California 19 Business & Professions Code sections 17200, et seq.; (6) violation of California’s 20 False Advertising Law (“FAL”), California Business & Professions Code sections 21 17500, et seq.; and (7) violation of Florida’s Deceptive & Unfair Practices Act 22 (“FDUTPA”), Florida Statutes Annotated sections 501.201, et seq. (See generally id.) 23 Now, Defendants move to stay the case under the primary jurisdiction doctrine or, 24 alternatively, to dismiss the FAC. (MTS 1; MTD 1–2.) 25 26 27 28 1 III. MOTION TO STAY 2 First, the Court addresses Defendants’ Motion to Stay under the primary 3 jurisdiction doctrine, pending regulatory guidance from the FDA.2 (MTS 1.) “The 4 primary jurisdiction doctrine allows courts to stay proceedings or to dismiss a 5 complaint without prejudice pending the resolution of an issue within the special 6 competence of an administrative agency.” Clark v. Time Warner Cable, 523 F.3d 7 1110, 1114 (9th Cir. 2008). This doctrine is “a prudential one,” and permits the courts 8 to stay “an otherwise cognizable claim [if it] implicates technical and policy questions 9 that should be addressed in the first instance by the agency with regulatory authority 10 over the relevant industry rather than by the judicial branch.” Id. However, primary 11 jurisdiction only “applies in a limited set of circumstances.” Id. at 1115. The doctrine 12 “is to be used only if a claim requires resolution of an issue of first impression, or of a 13 particularly complicated issue that Congress has committed to a regulatory agency.” 14 Id. at 1114. Not all claims within an agency’s purview need be decided by the 15 agency, and the doctrine is not “intended to secure expert advice for the courts from 16 regulatory agencies every time a court is presented with an issue conceivably within 17 the agency’s ambit.” Syntek Semiconductor Co. v. Microchip Tech. Inc., 307 F.3d 18 775, 780 (9th Cir. 2002). 19 “No fixed formula exists for applying the doctrine of primary jurisdiction.” 20 United States v. W. Pac. R.R. Co., 352 U.S. 59, 64 (1956). “[T]he question is a matter 21 for the court’s discretion,” and the Ninth Circuit has typically invoked the doctrine 22 where there is “(1) the need to resolve an issue that (2) has been placed by Congress 23 within the jurisdiction of an administrative body having regulatory authority 24 (3) pursuant to a statute that subjects an industry or activity to a comprehensive 25 2 The Court GRANTS Defendants’ Request for Judicial Notice of documents published by the FDA 26 and legislative authorities regarding the pending FDA guidelines. (Req. Judicial Not. ISO MTS, ECF No. 66.) See Lee v. City of Los Angeles, 250 F.3d 668, 688 (9th Cir. 2001) (granting judicial 27 notice for “matters of public record” that are not “subject to reasonable dispute”); United States v. 28 Ritchie, 342 F.3d 903, 909 (9th Cir. 2003) (granting judicial notice for “records and reports of administrative bodies”). 1 regulatory authority that (4) requires expertise and uniformity in administration.” 2 Syntek, 307 F.3d at 781 (citing United States v. Gen. Dynamics Corp., 828 F.2d 1356, 3 1362 (9th Cir. 1987)). At bottom, “efficacy is the deciding factor in whether to invoke 4 primary jurisdiction,” and it need not be invoked “when a referral to the agency would 5 significantly postpone a ruling that a court is otherwise competent to make.” Astiana 6 v. Hain Celestial Grp., Inc., 783 F.3d 753, 760–61 (9th Cir. 2015). 7 Here, Defendants contend that each relevant factor is met because (1) the FDA 8 has regulatory authority over CBD products under the Agricultural Improvement Act 9 of 2018 (“2018 Farm Bill”), Public Law No. 115–334; (2) pending FDA guidelines 10 are necessary to resolve a material issue because the FDA is developing “validated 11 testing . . . to support the manufacturing of safe and consistent CBD products”; and 12 (3) there is a need for uniform application of forthcoming FDA guidelines on CBD 13 products. (MTS 8–11.) In opposition, Plaintiff contends that the Court is competent 14 to resolve this matter without the pending FDA guidelines. (Opp’n MTS 4.) Plaintiff 15 is correct. 16 The heart of Plaintiff’s claim is that Defendants “overstate[d] the quantity of 17 CBD contained in their [p]roducts.” (FAC ¶ 2.) For the FDA to have primary 18 jurisdiction over this matter, its forthcoming guidelines must affect labeling standards 19 for disclosing CBD content. However, the pending FDA guidelines mainly concern 20 the sale of CBD products as medicine or dietary supplements with “unsubstantiated 21 therapeutic claims,” which violates the law and puts patients at risk. (Not.

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Miguel Rodriguez v. Just Brands USA, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/miguel-rodriguez-v-just-brands-usa-inc-cacd-2021.