Roland v. Letgo

CourtCourt of Appeals for the Tenth Circuit
DecidedFebruary 1, 2024
Docket22-1456
StatusUnpublished

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

Bluebook
Roland v. Letgo, (10th Cir. 2024).

Opinion

Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 1 FILED United States Court of Appeals UNITED STATES COURT OF APPEALS Tenth Circuit

FOR THE TENTH CIRCUIT February 1, 2024 _________________________________ Christopher M. Wolpert Clerk of Court MADISON ROLAND, individually; GINA HARRIS, as legal guardian to Layla Roland, Joseph Roland, Mason Roland, and Lily Roland, minor children of and legal heirs to Joseph and Jossline Roland; SAMMI HECKERMAN, as personal representative of Decedent, Estate of Jossline Roland; ROSA BILBREY, as personal representative of the Estate of Joseph Roland, Nos. 22-1456, 23-1014 & 23-1012 (D.C. No. 1:22-CV-00899-MEH) Plaintiffs - Appellants/Cross- (D. Colo.) Appellees,

v.

LETGO, INC; OFFERUP, INC.,

Defendants - Appellees/Cross- Appellants.

_________________________________

ORDER AND JUDGMENT* _________________________________

Before TYMKOVICH, MATHESON, and CARSON, Circuit Judges. _________________________________

Letgo is an online marketplace and mobile application that pairs unaffiliated

sellers and prospective buyers. Joseph and Jossline Roland used Letgo’s app to

* This order and judgment is not binding precedent, except under the doctrines of law of the case, res judicata, and collateral estoppel. It may be cited, however, for its persuasive value consistent with Fed. R. App. P. 32.1 and 10th Cir. R. 32.1. Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 2

arrange for the purchase of a car for their 17-year-old daughter. Tragically, the seller

of the car was an imposter. When the Rolands met him to consummate the purchase,

he murdered them both and stole $3,000.

Plaintiffs—the Rolands’ estate—sued Letgo, alleging a number of Colorado

state law tort and consumer protection claims, and one claim based on federal law.

The district court dismissed plaintiffs’ tort claims because they did not plausibly

allege Letgo made false or misleading representations, increased the risk of harm to

the Rolands, or caused their deaths. And it dismissed the consumer protection claim

because plaintiffs failed to plausibly allege Letgo knowingly engaged in a deceptive

trade practice, that it acted recklessly or willfully, or intended to induce the Rolands

to transact with Mr. Brown.

Because we agree the amended complaint fails to plausibly allege a cause of

action under Colorado law, we AFFIRM.

I. Background1

A. The Letgo Platform

At the time of the crimes, Letgo was a website and mobile application that

allowed users to “buy from, sell to and chat with others locally.” Aplt. App. at

00012.2 It allows users to browse items for sale locally, view each other’s profiles,

1 These facts are taken from plaintiffs’ amended complaint and documents incorporated by reference. 2 The other defendant, OfferUp—a similar platform, acquired Letgo shortly before this litigation. 2 Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 3

and send messages to coordinate a purchase. Letgo competed against other online

marketplaces, such as eBay and Craigslist.

To distinguish itself, Letgo advertised its “Verified User” feature. After users

created an account and accessed the Letgo marketplace, they were encouraged to

“verify” their profile. To receive a “Verified User” badge on your profile, users had

to supply enough personal information to reach 50 points. For example, a profile

photo was 10 points, a phone number was 15 points, an email address was 5 points, a

linked Facebook account was 25 points, and a government-issued ID was 40 points.

Id. at 00117. The user’s profile would then reflect they were “verified with”

whatever methods the user chose. If a user submitted an email address or phone

number, their profile would reflect they were “verified with” an email or phone

number. But until a user reached 50 points, their profile would prompt other users to

request that they “verify” their profile. In other words, to become a “Verified User,”

you would have to supply more than just a phone number and an email address.

The Letgo website explained it used “machine learning” to identify and block

inappropriate content (such as stolen merchandise) and worked closely with local law

enforcement to ensure the “trust and safety of the tens of millions of people who use

Letgo.” Aplt. App. at 00013. It also promoted “anti-fraud technology” to help detect

possible scams. But Letgo still encouraged users to only communicate through the

app and to not share any other personal information. It reminded users to take proper

precautions when buying or selling online, to meet in a public place during the day,

3 Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 4

and to consult third party sources to check a vehicle’s history for theft. Aplt. App. at

00145-46.

Joseph and Jossline Roland wanted to buy a car for their eldest daughter and

used Letgo to see if anyone in their area was selling one. They found a listing posted

by Kyree Brown, who created his user profile under the pseudonym “James Worthy.”

Mr. Brown posted a 2017 Toyota Rav 4 LE AWD for sale. The advertised car had

been stolen a few days before. His profile indicated he was “verified with” his phone

number, but users were prompted to “ask [him] to verify [his] profile.” He had no

profile photo, no reviews, and no “Verified User” badge:

Aplt. App. at 00079.

4 Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 5

B. The Murders

On August 14, 2020, the Rolands agreed to meet Mr. Brown in a PETCO

parking lot at 11 p.m. to purchase the car. When Mr. Brown arrived, he said he

brought the wrong title for the car and asked the Rolands to follow him to his

fictitious residence so he could retrieve the correct title. But Mr. Brown did not have

the vehicle title because the car was stolen. The Rolands agreed to follow him to the

second location. When they arrived at an apartment complex, Mr. Brown approached

the driver’s side window with a handgun and demanded the money. Mr. Roland

attempted to grab the gun. Mr. Brown, intending to shoot Mr. Roland, accidentally

struck and killed Mrs. Roland. He then killed Mr. Roland and stole the $3,000 they

brought to purchase the car. Law enforcement found Mr. and Mrs. Roland

unresponsive in their vehicle. They were declared dead just after midnight on

August 15, 2020, leaving behind five minor children.

Law enforcement made contact with the Roland residence and obtained access

to Mr. Roland’s iPhone and reviewed the communications with Mr. Brown via the

Letgo app. Letgo gave law enforcement the information it had on the “James

Worthy” account—which was only an email address. Meanwhile, Mr. Brown set the

car on fire and deleted his “James Worthy” account. To engage in further criminal

activity, Mr. Brown created another Letgo account using a different pseudonym with

the same photos of the stolen (and now destroyed) car.

Twelve days after the murders, Verizon Wireless confirmed the location data

of the phones used in the PETCO parking lot, at the apartment complex, and at the

5 Appellate Case: 22-1456 Document: 010110993395 Date Filed: 02/01/2024 Page: 6

location the car was destroyed.

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