Russell v. Walmart Inc.

CourtDistrict Court, N.D. California
DecidedJuly 5, 2023
Docket4:22-cv-02813
StatusUnknown

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

Bluebook
Russell v. Walmart Inc., (N.D. Cal. 2023).

Opinion

1 2 3 4 UNITED STATES DISTRICT COURT 5 NORTHERN DISTRICT OF CALIFORNIA 6 7 DEBORAH RUSSELL, Case No. 22-cv-02813-JST

Plaintiff, 8 v. ORDER GRANTING MOTION TO 9 DISMISS

10 WALMART, INC., Re: ECF No. 32 Defendant. 11

12 13 Before the Court is Defendant Walmart, Inc.’s motion to dismiss. ECF No. 32. The Court 14 will grant the motion. 15 I. BACKGROUND 16 For the purposes of the present motion, the Court accepts as true the following facts in the 17 amended complaint. Walmart is a large retailer that operates many stores in California. Id. ¶ 7. 18 To pay for the items they wish to purchase, Walmart’s customers may choose between using 19 customer-operated self-checkout or having a Walmart-employed cashier check out their items. Id. 20 ¶¶ 13, 17. Plaintiff Deborah Russell shops at one or more Walmart stores and has performed 21 many of the same tasks as a Walmart cashier, without compensation, by using self-checkout. ECF 22 No. 31 ¶ 22. Walmart invites, encourages, and requests customers to use self-checkout instead of 23 checkout lanes operated by Walmart-employed cashiers. Id. ¶¶ 25-27. As a result, Walmart now 24 employs fewer cashiers, which in turn further induces customers to use self-checkout to avoid 25 longer checkout lines. Id. ¶ 28. In using self-checkout, customers perform what Russell argues 26 amounts to “uncompensated work” from which Walmart benefits by lowering its own payroll 27 costs. Id. ¶ 23. Media reports suggest that the use of self-checkout could potentially expose 1 risk. Id. ¶ 38. 2 Russell filed suit on behalf of a putative class, alleging that Walmart owed her unpaid 3 wages for the time she had spent at self-checkout. ECF No. 1-1. The Court dismissed Russell’s 4 initial complaint with leave to amend, concluding that Russell’s “efforts in using Walmart’s self- 5 checkout apparatus did not constitute ‘work’” under California law. ECF No. 30 at 4-5. 6 Russell filed an amended complaint asserting a single claim “for restitution under theory of 7 quasi-contract and/or unjust enrichment” and alleging that customers who choose self-checkout 8 confer a benefit that would be inequitable for Walmart to retain. ECF No. 31 ¶¶ 34-39. Walmart 9 now moves to dismiss the amended complaint. ECF No. 32. 10 II. JURISDICTION 11 This Court has subject matter jurisdiction under 28 U.S.C. § 1332(d)(2). 12 III. LEGAL STANDARD 13 “Dismissal under Rule 12(b)(6) is appropriate only where the complaint lacks a cognizable 14 legal theory or sufficient facts to support a cognizable legal theory.” Mendiondo v. Centinela 15 Hosp. Med. Ctr., 521 F.3d 1097, 1104 (9th Cir. 2008). To survive a motion to dismiss, “a 16 complaint must contain sufficient factual matter, accepted as true, to ‘state a claim to relief that is 17 plausible on its face.’” Ashcroft v. Iqbal, 556 U.S. 662, 678 (2009) (quoting Bell Atlantic Corp. v. 18 Twombly, 550 U.S. 544, 570 (2007)). “A claim has facial plausibility when the plaintiff pleads 19 factual content that allows the court to draw the reasonable inference that the defendant is liable 20 for the misconduct alleged.” Id. In determining whether a plaintiff has met the plausibility 21 requirement, a court must “accept all factual allegations in the complaint as true and construe the 22 pleadings in the light most favorable to the nonmoving party.” Knievel v. ESPN, 393 F.3d 1068, 23 1072 (9th Cir. 2005). 24 IV. DISCUSSION 25 Walmart relies on outdated caselaw to argue that unjust enrichment is not a cause of action 26 under California law. More recent authority, however, confirms that both the Ninth Circuit and 27 the California Supreme Court construe California law to permit a cause of action for unjust 1 that plaintiff sufficiently pleaded unjust enrichment “as an independent cause of action or as a 2 quasi-contract claim for restitution”); Hartford Casualty Ins. Co. v. J.R. Marketing, L.L.C., 61 Cal. 3 4th 988, 1000 (2015) (holding that none of the “numerous objections to the proposition that a 4 direct action . . . for unjust enrichment can lie . . . compels the conclusion that such a claim is 5 absolutely foreclosed”). 6 In the alternative, Walmart argues that Russell fails to sufficiently plead the elements of an 7 unjust enrichment claim. “To allege unjust enrichment as an independent cause of action, a 8 plaintiff must show that a defendant received and unjustly retained a benefit at the plaintiff’s 9 expense.” ESG, 828 F.3d at 1038. Russell alleges that customers confer a benefit on Walmart 10 when providing uncompensated labor as a substitute for the work of regularly employed Walmart 11 cashiers. ECF No. 31 ¶ 35. 12 Russell’s allegation is insufficient. “Restitution is not mandated merely because one 13 person has realized a gain at another’s expense,”; “[r]ather, the obligation arises when the 14 enrichment obtained lacks any adequate legal basis and thus ‘cannot conscientiously be retained.’” 15 Hartford, 61 Cal. 4th at 998 (quoting Restatement (Third) of Restitution & Unjust Enrichment § 1 16 cmt. b (Am. L. Inst. 2011)). Thus, restitution generally requires “that a defendant has been 17 unjustly conferred a benefit ‘through mistake, fraud, coercion, or request.’” Astiana v. Hain 18 Celestial Grp., Inc., 783 F.3d 753, 762 (9th Cir. 2015) (emphasis added) (quoting 55 Cal. Jur. 3d 19 Restitution § 2 (2015)). In other words, it is not enough that Russell have provided Walmart with 20 a beneficial service; Russell must also allege that Walmart unjustly secured that benefit through 21 qualifying conduct. Absent qualifying mistake, fraud, coercion, or request by Walmart, there is no 22 injustice. Regents of Univ. of Cal. v. LTI Flexible Prods., Inc., No. 20-cv-08686-WHO, 2021 WL 23 4133869, at *10 (N.D. Cal. Sept. 10, 2021) (“Under California law, ‘[i]t must ordinarily appear 24 that the benefits were conferred by mistake, fraud, coercion or request; otherwise, though there is 25 enrichment, it is not unjust.’” (quoting Nibbi Bros., Inc. v. Home Fed. Sav. & Loan Ass’n, 205 Cal. 26 App. 3d 1415, 1422 (1988)). 27 Russell fails to adequately allege that Walmart has engaged in qualifying conduct 1 encouraged, and requested” customers’ use of self-checkout stands through “fishing.” ECF No. 31 2 ¶ 39. Russell quotes a retail industry publication that defines fishing as the practice of assigning 3 employees as self-checkout attendants who “encourag[e] shoppers to come use the self-service and 4 help[] where necessary.” Id. ¶ 27. Russell does not allege that she ever encountered fishing at any 5 Walmart, or that such fishing induced her use of self-checkout. Moreover, even if she had made 6 such an allegation, such “encourag[ement]” does not constitute a request of the sort that can 7 provide a basis for unjust enrichment. See Dinosaur Dev., Inc. v. White, 216 Cal. App. 3d 1310, 8 1316 (1989) (interpreting “request,” for the purposes of unjust enrichment, to mean a “direct 9 request” (emphasis added)).1 Russell does not allege that any Walmart employee directly 10 requested that she or anyone else use the self-checkout stand in lieu of having their items checked 11 out by an employee. In fact, Russell expressly alleges that customers “have a choice” between the 12 two. ECF No. 31 ¶ 17.

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Russell v. Walmart Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/russell-v-walmart-inc-cand-2023.