Pettitt v. The Procter & Gamble Distributing LLC

CourtDistrict Court, N.D. Illinois
DecidedJune 5, 2025
Docket1:25-cv-00800
StatusUnknown

This text of Pettitt v. The Procter & Gamble Distributing LLC (Pettitt v. The Procter & Gamble Distributing LLC) is published on Counsel Stack Legal Research, covering District Court, N.D. Illinois primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Pettitt v. The Procter & Gamble Distributing LLC, (N.D. Ill. 2025).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE NORTHERN DISTRICT OF ILLINOIS EASTERN DIVISION

JACQUELIN PETTITT, on behalf of Plaintiff and ) the class members described herein, ) ) Plaintiffs, ) No. 25 C 800 ) v. ) Judge Robert W. Gettleman ) PROCTER & GAMBLE ) DISTIRBUTING LLC, ) ) Defendant. )

MEMORANDUM OPINION & ORDER Plaintiff Jacquelin Pettitt, on behalf of herself and a putative class, brings a three-count class action complaint against defendant Procter & Gamble Distributing, LLC (“P&G”). Count I alleges a violation of the Illinois Prizes and Gifts Act (“IPGA”), Count II alleges a violation the Illinois Consumer Fraud Act (“ICFA”), and Count III alleges breach of contract. P&G moves to dismiss the complaint (Doc. 15) and to strike the class allegations (Doc. 16). For the reasons explained below, the motion to strike is construed as a motion to dismiss and is granted. BACKGROUND No matter the outcome of this case, plaintiff’s prize is bound to be flushed down the drain. P&G markets, sells, distributes, and promotes Charmin, a popular brand of toilet paper. In 2024, P&G conducted a monthly sweepstakes to promote the sale of Charmin toilet paper. To enter the sweepstakes, participants were asked to provide their email addresses and answer a series of questions about their households, their shopping habits, and the cartoon bear characters that P&G uses in Charmin advertising and packaging. The prize on offer was “a year’s worth of Charmin” in the form of 12 monthly deliveries of an 18-pack of Charmin Super Mega toilet paper to the winner’s home.

Plaintiff is a resident of Illinois who entered the Charmin sweepstakes. She provided her email address and answered the questions. On December 16, 2024, P&G emailed plaintiff notifying her that she was “this month’s Charmin Sweepstakes WINNER!” On the same day, about 8 hours later, P&G emailed plaintiff informing her that the original message was sent in error and that she would receive instructions on how to claim a $2 Charmin coupon. On the following day, P&G sent another follow up email offering two $25 coupons. On December 18, plaintiff inquired as to what had happened, and P&G responded again explaining that “[t]he

email you received stating that you were the winner of the Charmin Super Mega Sweepstakes was sent in error.” DISCUSSION

The court begins with defendant’s motion to strike class allegations. Before reaching the substance of the motion, the court must address a procedural issue. Defendant styles its motion as a motion to strike. Rule 12(f) provides that “[t]he court may strike from a pleading an insufficient defense or any redundant, immaterial, impertinent, or scandalous matter.” Fed. R. Civ. P. 12(f). Motions to strike are appropriate to “remove unnecessary clutter from the case,” but they are generally disfavored in this circuit because they are often employed for the sole purpose of causing delay. Heller Fin., Inc. v. Midwhey Powder Co., 883 F.2d 1286, 1294 (7th

Cir. 1989). Nevertheless, some courts in this circuit have held that it is appropriate to strike class allegations at the pleading stage “where the pleadings are facially defective or inherently deficient.” Dowding v. Nationwide Mutual Insurance Co., 490 F. Supp. 3d 1291, 1298 (N.D. Ill. 2020); see also, e.g., Buonomo v. Optimum Outcomes, Inc., 301 F.R.D. 292, 295 (N.D. Ill. 2014) (explaining that “[i]f the plaintiff's class allegations are facially and inherently deficient, for example, a motion to strike class allegations ... can be an appropriate device to determine

whether [the] case will proceed as a class action” (internal quotations omitted)); Wolfkiel v. Intersections Ins. Servs. Inc., 303 F.R.D. 287, 292 (N.D. Ill. 2014) (similar). Instead of following that route, this court finds that it is more appropriate to construe defendant’s motion as a motion to dismiss under Rule 12(b)(6). Plaintiff’s class allegations are not a “defense.” Nor are they “redundant, immaterial, impertinent, or scandalous.” Fed. R. Civ.

P. 12(f). The class allegations are material and pertinent to the dispute, a far cry from “unnecessary clutter.” Heller 883 F.2d at 1294. Instead, defendant’s motion argues that plaintiff cannot state a class action claim upon which the court can grant relief because the terms of the contract between plaintiff and defendant preclude such a claim as a matter of law. While defendant may have styled its motion incorrectly, Rule 8(e) provides that “[p]leadings must be construed so as to do justice.” Fed. R. Civ. P 8(e). Accordingly, the court will evaluate defendant’s motion under the legal standard governing 12(b)(6) motions. Cf Boyack v. Regis Corporation, 812 F. App’x 428, 431 (9th Cir. 2020) (explaining that although “[t]he district court improperly struck [claims] under Federal Rule of Civil Procedure 12(f)”….because “Rule 12(f) allows a district court only to strike redundant, immaterial, or scandalous claims,” the court

nevertheless decided to “affirm the district court’s decision” because the “claims are properly dismissed pursuant to Rule 12(b)(6) for failure to state a claim”). Thus, the court will evaluate the motion to strike under the familiar principles of a motion to dismiss under Rule 12(b)(6). A motion to dismiss under Rule 12(b)(6) challenges the sufficiency of the complaint. Hallinan v. Fraternal Order of Police of Chi. Lodge No. 7, 570 F.3d 811, 820 (7th Cir. 2009). To survive a motion to dismiss, plaintiff must clear two hurdles: (1) “the complaint must describe the claim in sufficient detail to give the defendant fair notice of what the claim is and the grounds upon which it rests;” and (2) “its allegations must plausibly

suggest that the plaintiff has a right to relief, raising that possibility above a ‘speculative level.’” Tamayo v. Blagojevich, 526 F.3d 1074, 1084 (7th Cir. 2008). At this stage, “the court must construe all of the plaintiff’s factual allegations as true, and must draw all reasonable inferences in the plaintiff’s favor.” Virnich v. Vorwald, 664 F.3d 206, 212 (7th Cir. 2011). “A claim has facial plausibility when the plaintiff pleads factual content that allows the court to draw the reasonable inference that the defendant is liable for the misconduct alleged.” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009).

Addressing defendant’s motion, which this court construes as a motion to dismiss, defendant argues that the class allegations are barred by the terms of the contract. Defendant points out that rules of sweepstakes provide the following “You agree that: (a) any and all disputes, claims and causes of action arising out of, or connected with the Sweepstakes or any prizes awarded shall be resolved individually, without resort to any form of class action …” Defendant argues that it agrees with plaintiff that the sweepstakes rules formed a contract between defendant and plaintiff (and putative class members), and the court should enforce the contract pursuant to its terms.

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Related

Ashcroft v. Iqbal
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Pettitt v. The Procter & Gamble Distributing LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/pettitt-v-the-procter-gamble-distributing-llc-ilnd-2025.