Shellenberger v. AIG WarrantyGuard Inc

CourtDistrict Court, W.D. Washington
DecidedSeptember 11, 2024
Docket2:24-cv-00657
StatusUnknown

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

Bluebook
Shellenberger v. AIG WarrantyGuard Inc, (W.D. Wash. 2024).

Opinion

1 2

3 4 5 6 7 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 8 AT SEATTLE

9 10 HADASSAH SHELLENBERGER, CASE NO. C24-0657JLR 11 Plaintiff, ORDER v. 12 AIG WARRANTYGUARD, INC., et 13 al., 14 Defendants. 15 I. INTRODUCTION 16 Before the court are Defendant AIG WarrantyGuard, Inc.’s (“AIGWG”) and 17 Defendant Whirlpool Corporation’s (“Whirlpool” and together with AIGWG, 18 “Defendants”) motions to dismiss Plaintiff Hadassah Shellenberger’s putative class 19 action complaint. (AIGWG Mot. (Dkt. # 23); Whirlpool Mot. (Dkt. # 26); see also 20 AIGWG Reply (Dkt. # 42); Whirlpool Reply (Dkt. # 41); Compl. (Dkt. # 1).) Defendants 21 join in each other’s motions. (AIGWG Mot. at 2 n.2; Whirlpool Mot. at 9 n.1.) Ms. 22 1 Shellenberger opposes the motions. (AIGWG Resp. (Dkt. # 37); Whirlpool Resp. (Dkt. 2 # 38).) The court has considered the motions, the parties’ submissions in support of and

3 in opposition to the motions, the relevant portions of the record, and the applicable law. 4 Being fully advised,1 the court GRANTS Defendants’ motions. 5 II. BACKGROUND 6 Whirlpool manufactures home appliances under various brand names, including 7 KitchenAid. (Compl. ¶¶ 1, 20.) Together, Whirlpool and AIGWG “market, sell, and 8 administer” warranty plans to consumers who purchase Whirlpool appliances. (Id. ¶ 30.)

9 This putative class action concerns Ms. Shellenberger’s purchase of Defendants’ 10 warranty plan (the “Service Plan”), which provided inferior coverage than she expected 11 for her new KitchenAid dishwasher. Ms. Shellenberger alleges as follows. 12 Around April 2020, Ms. Shellenberger purchased a KitchenAid dishwasher at Best 13 Buy for $1,084.99, as well as a Geek Squad protection plan (“GSP Plan”) to cover the

14 repair costs of any potential malfunctions. (Id. ¶¶ 39-40.) Beginning around the same 15 time, Ms. Shellenberger began receiving marketing communications from Defendants. 16 (Id. ¶ 40.) One of these communications, which was either mailed or emailed to her, 17 urged her “to protect her investment by purchasing a KitchenAid Service Plan.” (Id.; see 18 also id. ¶ 41 (alleging Ms. Shellenberger continued to receive these marketing

19 communications through 2023, and attaching examples of letters that use “identical 20

21 1 AIGWG requests oral argument (AIGWG Mot. at 1), but the other parties do not (see Whirlpool Mot. at 1; AIG Resp. at 1; Whirlpool Resp. at 1). The court determines oral argument 22 would not aid in its disposition of the motions. See Local Rules W.D. Wash. LCR 7(b)(4). 1 language” as the original offer), Exs. 4-6 (“Mktg. Materials”).) This marketing offer 2 described the Service Plan as providing “repair or replacement benefits for covered

3 malfunctions at no out-of-pocket expenses to the consumer and paying for 100% of the 4 required parts and labor for such repairs.” (Id. ¶ 42.) The offer used KitchenAid 5 branding, claimed to provide “KitchenAid certified technicians using factory certified 6 parts,” and gave the option to select from a variety of term lengths. (Id. ¶¶ 42-43.) It also 7 contained a disclaimer that directed readers to a KitchenAid webpage for complete terms 8 and conditions. (See Mktg. Materials at 47.)2 At some point, Ms. Shellenberger visited

9 the KitchenAid website and viewed promotional language similar to what she had seen 10 on the mailers, though she does not remember exactly when she did so. (Compl. ¶ 46.) 11 After learning the Service Plan was cheaper than her GSP Plan, Ms. Shellenberger 12 called the number listed on Defendants’ marketing offer and bought a three-year Service 13 Plan over the phone. (Id. ¶¶ 47-48.) She subsequently received a confirmation email

14 with details about her Service Plan. (Id. ¶ 50.) Ms. Shellenberger alleges Defendants are 15 both parties to the Service Plan contract, with Whirlpool acting as “the Service Contract 16 Administrator,” and AIGWG as the “Obligor.” (Id. ¶¶ 2, 96; see also id. ¶ 13 n.3, Ex. 17 8 (“Contract”) at 60.) Ms. Shellenberger later canceled her GSP Plan, for which she 18 obtained a refund. (Compl. ¶ 52.)

19 Ms. Shellenberger’s dishwasher began malfunctioning soon after purchase. (Id. 20 ¶ 53.) She contacted Whirlpool and obtained a replacement gasket under the 21

2 The court refers to the page numbers contained in the CM/ECF header when citing to 22 exhibits attached to the complaint. 1 manufacturer’s warranty. (Id.) This fix did not last, however, because some time later 2 Ms. Shellenberger began observing similar problems with the gasket. (Id. ¶ 54.) In

3 September 2022, she submitted a claim under her Service Plan. (Id.) She also called 4 Whirlpool, although this time, the agent informed her that because “there were no 5 appointments available in [Whirlpool’s] network,” Ms. Shellenberger “could hire an 6 independent repair company to fix her appliance, pay out-of-pocket fees for the services,” 7 and then “seek reimbursement from Whirlpool.” (Id.) The Whirlpool agent also advised 8 that any third-party repair service must comply with various conditions before proceeding

9 with a repair, for example by performing a diagnostic test and sending a repair estimate to 10 Whirlpool. (Id. ¶ 55.) Ms. Shellenberger attempted to locate a suitable repair service but 11 “gave up” after approximately one week. (Id. ¶ 56.) 12 Ms. Shellenberger continued using the malfunctioning dishwasher until February 13 2023, when it stopped working. (Id. ¶¶ 56-57.) She submitted another claim to

14 Whirlpool under her Service Plan, but “was informed that, under the terms of her Service 15 Contract, her appliance would be bought out for $764.36.” (Id. ¶ 57.) When Ms. 16 Shellenberger asked whether a replacement was possible, the Whirlpool agent “told her 17 that she could either accept the Buyout or get nothing.” (Id.) Ms. Shellenberger used the 18 buyout payment—supplemented with her own funds—to purchase a new dishwasher.

19 (Id. ¶ 59.) Ms. Shellenberger also purchased a new warranty plan upon learning that her 20 Service Plan term ended at the time of the buyout. (Id. ¶ 58.) 21 Ms. Shellenberger initiated this action on May 10, 2024, claiming Defendants’ 22 marketing materials deceptively misrepresented and omitted material terms of the Service 1 Plan contract. (See generally id.) Ms. Shellenberger alleges Defendants’ marketing 2 impresses upon consumers that the Service Plans are related to, and offer coverage

3 benefits comparable to, the Whirlpool manufacturer’s warranty. (Id. ¶¶ 4-8.) But 4 according to Ms. Shellenberger, the Service Plans offer “inferior” coverage and allow 5 Defendants “to generate unfair profits for themselves at the expense of unsuspecting 6 consumers”—particularly through the buyout provision. (Id. ¶¶ 10, 68; see also id. 7 ¶¶ 8-12; Contract § 20 (permitting the buyout of an appliance, rather than repair or 8 replacement, at Defendants’ sole discretion).) Ms. Shellenberger asserts claims against

9 Defendants for: (1) violation of Washington’s Consumer Protection Act (“CPA”), ch. 10 19.86 RCW; (2) breach of contract; and (3) breach of the duty of good faith and fair 11 dealing. (Compl. ¶¶ 84-107.) Defendants each filed a motion to dismiss the complaint, 12 describing this case as a “copycat lawsuit” based on a similar putative class action that 13 Ms. Shellenberger’s attorney filed last year in the Central District of California.

14 (AIGWG Mot. at 1 & n.1 (citing Salas v. Whirlpool Corp., No. 5:23-CV-01549-AB-KK, 15 2024 WL 694067 (C.D. Cal. Jan. 24, 2024)); Whirlpool Mot. at 12 & n.3 (same).) The 16 court stayed discovery in this case pending resolution of Defendants’ motions to dismiss. 17 (8/19/24 Order (Dkt. # 44).) The motions are now ripe for decision. 18 III. ANALYSIS

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Shellenberger v. AIG WarrantyGuard Inc, Counsel Stack Legal Research, https://law.counselstack.com/opinion/shellenberger-v-aig-warrantyguard-inc-wawd-2024.