Scott v. Apple Inc.

CourtDistrict Court, District of Columbia
DecidedNovember 6, 2024
DocketCivil Action No. 2023-0475
StatusPublished

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

Bluebook
Scott v. Apple Inc., (D.D.C. 2024).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

RICKY SCOTT, individually and on behalf of the General Public of the District of Columbia,

Plaintiff, Civil Action No. 23-475 (RDM)

v.

APPLE INC.,

Defendant.

MEMORANDUM OPINION AND ORDER

Plaintiff Ricky Scott brings this putative class action against Defendant Apple Inc.,

alleging that Apple violated the D.C. Unfair and Deceptive Trade Practices Act, D.C. Code § 28-

3905, in marketing certain allegedly defective laptop computers and by allegedly breaching an

express or implied warranty. Dkt. 1-1 (Compl.). After removing the case from D.C. Superior

Court to this Court, Dkt. 1 (notice of removal), Apple filed the pending motion to dismiss

pursuant to Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). Dkt. 12. For the reasons

explained herein, the Court will GRANT in part and DENY in part that motion.

I. BACKGROUND

A. Factual & Procedural Background

For purposes of considering Apple’s motion to dismiss, the following allegations, which

are taken from Plaintiff’s Complaint, are accepted as true. See Tah v. Glob. Witness Publ’g, Inc.,

991 F.3d 231, 239 (D.C. Cir. 2021).

In the fall of 2016, Apple launched its fourth generation MacBook Pro models, which

“were up to 17% thinner than previous models.” Dkt. 1-1 at 12 (Compl. ¶ 25). Apple described

1 these MacBook Pros as “the thinnest and lightest [versions] ever, with the ‘best ever’ display.”

Id. To accomplish this design, Apple connected the display to a controller board using flexible

ribbon cables that were thinner than the larger gauge wire cables previously used. Id. (Compl.

¶ 26). Apple implemented this same essential design in its 2018, 2019, and 2020 MacBook Pros,

id. at 13 (Compl. ¶¶ 27–28), consistently advertising its “new True Tone technology in [the]

Retina display” as “the best ever,” id. at 13–14 (Compl. ¶ 30); see also id. at 15–17 (Compl.

¶¶ 33, 36); id. at 18 (Compl. ¶ 38).

Plaintiff alleges that, “[c]ontrary to [this] marketing, the [MacBook Pro] [l]aptops possess

a uniform physical defect that causes their displays and/or cameras to fail prematurely.” Id. at 19

(Compl. ¶ 41). In particular, “[b]eginning in the 2016 Models, Apple opted to use flexible—and

fragile—ribbon cables to connect the display to the t-con board inside the base enclosure.” Id.

(Compl. ¶ 42). These “cables are extremely thin,” which “helps them navigate the tight bends

along their circuitous route from the t-con board to the display.” Id. at 20 (Compl. ¶ 44).

Opening the laptops, however, “subjects the flex cables to bending stress,” and, “[o]ver time, this

stress causes the conductors in the flex cable to fatigue and, eventually, to fracture.” Id. (Compl.

¶ 45). “In addition to failures caused by bending stress, the flex cables are also vulnerable to

damage caused by dust and debris,” id. at 22 (Compl. ¶ 47), which can lead to “glitches . . . on

the display,” id. at 23 (Compl. ¶ 49).

Depending on the nature and extent of the damage to the flex cables, a user may

experience any of the following: (1) the “stage light” effect, whereby minor damage to the

backlight cable causes the backlight to exhibit alternatively bright and dim areas at the bottom of

the screen; (2) partial backlight failure; (3) complete backlight failure; (4) graphic glitches; or

(5) camera failure. Id. at 24–26 (Compl. ¶ 50). Without a functioning backlight, the computer

2 display will turn black, rendering the laptop unusable. Id. at 24–26 (Compl. ¶¶ 50–51). The

complaint further alleges that, in response to the defect, Apple added two millimeters to the

length of the flex cables, beginning with its 2018 MacBook Pros, and increased the thickness of

the protective material overlaying the cables in its 2020 MacBook Pros. Id. at 27–28 (Compl.

¶¶ 55–56). The problem, however, persisted. Id.

Apple provides MacBook Pro purchasers with a one-year written express warranty that

covers device defects. Id. at 47 (Compl. ¶ 107). Among other limitations, the warranty does not

cover “damage from accident, misuse, abuse, liquid contact, or other external causes.” Id.

(Compl. ¶ 108); see Dkt. 12-3 (Singh Decl., Ex. A). In addition to Apple’s general warranty

guarantees, Apple also implements “service programs,” under which Apple offers to repair

specific issues in specific products free of charge. See Apple Service Programs,

https://support.apple.com/service-programs. In May 2019, Apple implemented a repair service

program for the 2016 13-inch MacBook Pro to address the defect in the flex cables. Dkt. 1-1 at

26–27 (Compl. ¶ 54). But this service program did not apply to 15-inch or 16-inch MacBook

Pros or to any MacBook Pros released after 2016. Id. at 27 (Compl. ¶ 54).

In August 2020, Plaintiff purchased a 16-inch, 2019 MacBook Pro from Amazon.com

with a subscription to AppleCare+ (Apple’s extended warranty program) for approximately

$2,099. Id. at 10 (Compl. ¶ 19). Apple’s marketing of the 16-inch model specifically lauded its

superior display as “[i]mmersive,” “brilliant,” and “the ultimate pro notebook for the ultimate

user,” id. at 16–17 (Compl. ¶ 36), representations that Plaintiff alleges he relied upon in making

his purchase, id. at 11 (Compl. ¶ 22). About two months after he purchased the laptop, however,

the display started to show signs of the damage that can arise from regularly opening and closing

the laptop—namely, the “stage lighting” effect. Dkt. 13 at 16; see Dkt. 1-1 at 20–23 (Compl.

3 ¶¶ 45–48). About six months after he made the purchase, the display backlight failed

completely, rendering Plaintiff’s laptop unusable. Dkt. 13 at 16; see Dkt. 1-1 at 26 (Compl.

¶ 51). P2P Computer Solutions repaired the laptop under the AppleCare+ extended warranty

program, but because Apple identified the source of the problem as relating to accidental

damage, Plaintiff was required to pay a $99 deductible. Dkt. 1-1 at 11 (Compl. ¶ 21).

On January 10, 2023, Plaintiff initiated this action in D.C. Superior Court, seeking

monetary damages and injunctive relief pursuant to the D.C. Consumer Protection Procedures

Act. Id. at 62–63 (Compl. Prayer for Relief ¶¶ A–K). He brought the action individually and,

pursuant to D.C. Superior Court Rule of Civil Procedure 23, on behalf of a class of “[a]ll natural

persons who purchased [2018, 2019, and 2020 MacBook Pros (the “Class Laptops”)] while

residing in the District of Columbia,” with specified exclusions. Id. at 49 (Compl. ¶ 118). On

February 21, 2023, Apple removed the case to this Court pursuant to 28 U.S.C. §§ 1332, 1441,

and 1446. Dkt. 1. Subsequently, Apple moved to dismiss the complaint, Dkt. 12.

B. Statutory Background

Plaintiff alleges that Apple engaged in unfair and deceptive trade practices in violation of

the District of Columbia’s Consumer Protection Procedures Act (“CPPA”), D.C. Code § 28-3901

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