Silveira v. Commercial Specialty Truck Holdings, LLC

CourtDistrict Court, E.D. Kentucky
DecidedAugust 12, 2025
Docket5:25-cv-00048
StatusUnknown

This text of Silveira v. Commercial Specialty Truck Holdings, LLC (Silveira v. Commercial Specialty Truck Holdings, LLC) is published on Counsel Stack Legal Research, covering District Court, E.D. Kentucky primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Silveira v. Commercial Specialty Truck Holdings, LLC, (E.D. Ky. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION (at Lexington)

RODNEY SILVEIRA, individually and ) purportedly on behalf of all others ) similarly situated, ) ) Plaintiff, ) Civil Action No. 5: 25-048-DCR ) V. ) ) COMMERCIAL SPECIALTY TRUCK ) MEMORANDUM OPINION HOLDINGS, LLC, ) AND ORDER ) Defendant. )

*** *** *** *** Plaintiff Rodeny Silveira initiated this action, individually and purportedly on behalf of all others similarly situated, after cybercriminals accessed his sensitive data from Defendant Commercial Specialty Truck Holdings, LLC (“CSTH”). CSTH moved to dismiss insisting the plaintiff lacks Article III standing or, alternatively, for failure to state a claim under Rule 12(b)(6) of the Federal Rules of Procedure. [Record No. 13] CSTH’s motion will be granted in part and denied in part for the reasons that follow. I. Background Silveira was formerly employed by Bridgeport Truck Manufacturing, which was later acquired by CSTH. [Record No. 1 at ¶ 36] Defendant CSTH “is a specialty vehicle manufacturer based in Cynthiana, Kentucky [that] operates through several brands including Continental Micers, E-Z Pack Trucks, One Source Parts, and Dynamic Towing and Manufacturing.” Id. at ¶ 2. On August 13, 2024, CSTH “became aware of suspicious activity occurring within [its] network.” Id. at ¶ 17. It was not until February 11, 2025, that Silveira received a data breach notice explaining that his personal identifiable information and protected health information

(collectively “PII/PHI”) may have been exposed in the breach. Id. at ¶ 36. By then, the PII/PHI was not merely accessed and viewed by cybercriminals but was also downloaded and stolen. Id. at ¶ 18 (explaining in data breach notice that “certain files and folders were copied from the CSTH environment without authorization on or about August 7, 2024”). The notorious ransomware group INC Ransom took credit for the data breach and posted confidential documents from E-Z Pack (a subsidiary of CSTH) to its dark web website. Id. at ¶¶ 30–34. The cybercriminals accessed CSTH’s systems for at least a week before CSTH

uncovered the breach. See id. at ¶¶ 17–18. During that time, the hackers had access to CSTH’s former and current employees PII/PHI, including their names, addresses, Social Security numbers, health insurance information, and medical information. Id. at ¶ 19. Despite the broad swath of data exposed, CSTH waited six months before notifying the individuals affected by the breach. Id. at ¶ 20. Since the data breach, Silveira has seen a “dramatic increase in in spam text messages—

about 20 to 30 per day—purporting to be about loans.” Id. at ¶ 44. He understands this to mean “that his PII has already been placed in the hands of cybercriminals” as he has not taken out any such loans. See id. The data breach has necessitated greater supervision of his personal data and added ongoing stress, fear, and anxiety. Id. at ¶¶ 46–48. Silveira brought this purported class action on behalf of himself and all others similarly situated. He asserts claims against CSTH for negligence (Count I), negligence per se (Count II), breach of implied contract (Count III), breach of implied covenant of good faith and fair dealing (Count IV), invasion of privacy (Count V), unjust enrichment (Count VI), breach of fiduciary duty (Count VII), breach of confidence (Count VIII), violation of Kentucky Consumer Protection Act (Count IX), and declaratory judgment (Count X). [Record No. 1]

The defendant moved to dismiss under Rules 12(b)(1) and (b)(6) of the Federal Rules of Civil Procedure, arguing that the plaintiff lacked standing and failed to state a claim on all counts. [Record No. 13] Silveira voluntarily withdrew his claims for negligence per se, breach of implied covenant of good faith and fair dealing, breach of confidence, and violation of Kentucky Consumer Protection Act. [Record No. 21 at 17 n.4] He also requested leave to amend his Complaint should the Court find any count inadequately pled. Id. at 25. II. Analysis (Subject Matter Jurisdiction)

A. Article III Standing A plaintiff must demonstrate that the court has subject matter jurisdiction to overcome dismissal under Rule 12(b)(1) of the Federal Rules of Civil Procedure. Madison-Hughes v. Shalala, 80 F.3d 1121, 1130 (6th Cir. 1996). The irreducible constitutional minimum for standing requires: (1) “injury in fact,” (2) “a causal connection between the injury and the conduct complained of,” and (3) a likelihood that “the injury will be ‘redressed by a favorable

decision.’” Carman v. Yellen, 112 F.4th 386, 399 (6th Cir. 2024) (quoting Lujan v. Defs. of Wildlife, 504 U.S. 555, 560–61 (1992)). For injury in fact, a plaintiff must demonstrate “a concrete and particularized, actual or imminent invasion of a legally protected interest.” Lujan, 504 U.S. at 555. Various intangible harms such as reputational harm, disclosure of private information, and intrusion upon seclusion also can constitute concrete harms. TransUnion LLC v. Ramirez, 594 U.S. 413, 425 (2021) (citations omitted). “‘The party invoking federal jurisdiction’ must establish these elements commensurate with the burden of proof required at each stage of a litigation.” Carman, 112 F.4th at 399 (quoting Lujan, 504 U.S. at 561). For example, the burden at the pleading stage only requires

a plaintiff to “plausibly assert standing.” Christian Healthcare Centers, Inc. v. Nessel, 117 F.4th 826, 842 (6th Cir. 2024) (citing Ass’n of Am. Physicians & Surgeons v. FDA, 13 F.4th 531, 543–44 (6th Cir. 2021)). Whereas “at the summary judgment stage, such a party can no longer rest on . . . mere allegations, but must set forth by affidavit or other evidence specific facts” to show standing. Clapper v. Amnesty Int’l USA, 568 U.S. 398, 412 (2013) (citations and quotations omitted). When a defendant mounts a facial challenge to subject matter jurisdiction based on a lack of standing, the court treats “the allegations in those pleadings as

true” and construes all reasonable inferences in the plaintiff’s favor. Christian Healthcare Centers, Inc., 117 F.4th at 842 (citing Ass’n of Am. Physicians & Surgeons, 13 F.4th at 543– 44; Parsons v. U.S. Dep’t of Justice, 801 F.3d 701, 710 (6th Cir. 2015)). Defendant CSTH makes a facial attack to the plaintiff’s standing to bring these claims. [Record No. 13] It argues that the Complaint fails to assert an Article III injury which is fairly traceable to CSTH’s conduct. More specifically, CSTH insists that Silveira does not establish

a sufficient injury for the alleged increase in spam text messages, time and effort spent monitoring his accounts, risk of future identity theft, violation of privacy, and diminution in the value of his personal information. Id. at 4–10. It further contends that Silveira does not show traceability from its conduct for any of the above alleged injuries. Id. at 10–11. But Silveira insists he has Article III standing because he has “suffered presently felt harm fairly traceable to the Data Breach including fraudulent misuse of the PHI/PII unauthorizedly disclosed, invasion of [his] privacy rights, diminution in value of the data, lost time, and emotional distress, as well as risk of imminent future harm.” [Record No.

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Silveira v. Commercial Specialty Truck Holdings, LLC, Counsel Stack Legal Research, https://law.counselstack.com/opinion/silveira-v-commercial-specialty-truck-holdings-llc-kyed-2025.