State Of Washington, Resp/x-app v. The Mandatory Poster Agency Inc, Apps/x-resps

199 Wash. App. 506
CourtCourt of Appeals of Washington
DecidedJuly 3, 2017
Docket74978-1-I
StatusPublished
Cited by16 cases

This text of 199 Wash. App. 506 (State Of Washington, Resp/x-app v. The Mandatory Poster Agency Inc, Apps/x-resps) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State Of Washington, Resp/x-app v. The Mandatory Poster Agency Inc, Apps/x-resps, 199 Wash. App. 506 (Wash. Ct. App. 2017).

Opinion

Verellen, C.J.

¶1 The first element of a Consumer Protection Act (CPA) violation is an unfair or deceptive act or practice. 1 An act is deceptive if it is likely to mislead a reasonable consumer. Such an act satisfies the first element if it has the capacity to deceive a substantial portion of the public. When the underlying facts are undisputed, the question whether the acts are likely to mislead—an objective inquiry—is a question of law. Whether such a deception has the capacity to reach a substantial portion of the public is a question of fact precluding summary judgment, unless the undisputed facts establish that capacity.

¶2 Here, the undisputed facts show the Mandatory Poster Agency Inc. (MPA) sent mass mailings under the assumed name Corporate Records Service (CRS) to more than 79,000 Washington corporations. As a matter of law, the undisputed format, images, and content of the mailings created a net impression likely to mislead a reasonable consumer into believing that CRS is associated with a *513 governmental agency and that the recipients were obligated to fill out and return the solicitations with a fee of $125. Notably, the mass mailings included language, tone, and imagery prohibited by MPA’s 2008 “Assurance of Discontinuance,” and such violations are prima facie evidence of a CPA violation.

¶3 Further, the undisputed scope of the extensive mass mailings generating payments by 2,901 consumers reveals a capacity to reach and thus deceive a substantial portion of the public. The trial court did not err in granting summary judgment that MPA engaged in a deceptive act or practice.

¶4 CRS contends the $793,540 penalty imposed by the court is excessive. On cross appeal, the State argues the penalty is too lenient. The trial court did not abuse its broad discretion in setting a penalty of $10 per mailing, together with a provision requiring CRS to fund restitution.

¶5 The trial court adequately engaged in a lodestar calculation of attorney fees but failed to make the required findings for an award of nonlawyer time. And the trial court should not have awarded expert witness fees as costs.

¶6 Because the State is the prevailing party on appeal, it is entitled to fees on appeal.

¶7 We affirm in part and reverse in part.

FACTS

¶8 Steven Fata, Thomas Fata, and Joseph Fata each own one-third of MPA and jointly undertake all corporate decisions. CRS has a mailbox in Olympia, Washington, at a United Parcel Service store.

¶9 Several years ago, the Attorney General’s Office initiated an investigation into MPA’s mass marketing of posters summarizing state and federal legal requirements. The State alleged MPA used mailers with various business names to deceive consumers into believing they must purchase posters from the company in order to comply with *514 state and federal law. The MPA advertisements appeared to originate from the government or an organization associated or in contact with the government. The ads also used names that evoked “an official government tone” and emblems that “mimic a state agency emblem.” 2 The ads also used a postal drop box with an Olympia address. The language suggested a necessity to act, such as “ ‘Advisory/ ” “ ‘advisement/ ” “ ‘achieve compliance/ ” and “ ‘effective immediately.’ ” 3

¶10 In February 2008, at the conclusion of the Attorney General Office’s investigation, MPA entered into an Assurance of Discontinuance prohibiting the company and its officers, directors, and principals from engaging in a variety of unfair or deceptive practices, including sending misleading solicitations to consumers that create the impression that the solicitations are from a government agency. The Assurance of Discontinuance also barred the use of specific terms and practices, along with the following provision:

This Assurance of Discontinuance shall not be considered an admission of violation of the Consumer Protection Act for any purposes, but failure to comply with this Assurance of Discontinuance shall be prima facie evidence of violations of RCW 19.86.020, thereby placing upon the Respondents, and their officers, directors, and principals, the burden of defending against imposition by the court of damages, injunctions, restitution, civil penalties of up to $2,000.00 per violation and costs including reasonable attorney’s fees. In addition, pursuant to RCW 19.86.140[,] violations of the injunctive provisions of this Assurance of Discontinuance may result in court imposed civil penalties of up to $25,000.00.[ 4 ]

¶11 In 2012 and 2013, CRS sent “Annual Minutes Records Form” solicitations to Washington consumers. Joseph Fata designed the solicitation; Steven Fata and Thomas Fata approved its use in Washington.

*515 ¶12 CRS mailed 79,354 solicitations to Washington consumers. The front of each envelope contained the language “IMPORTANT” in bold above “Annual Minutes Requirement Statement,” “TIME SENSITIVE,” and “If addressed name is incorrect, please forward this document to an authorized employee representative immediately.” 5 The green colored envelope included a stylized eagle symbol in the upper right-hand corner and an Olympia return address. A notation that “THIS IS NOT A GOVERNMENT DOCUMENT” was located just below the return address. 6

¶13 Inside the envelope, CRS included a form entitled “2012 - ANNUAL MINUTES RECORDS FORM.” 7 The form was addressed to the recipient’s business and contained a key code, a bar code, a response date, and the recipient’s date of incorporation. Each solicitation, excluding the February 2013 mailings, also included the “Corporation Number,” consisting of the uniform business identifier number assigned by the State to the corporation. 8 The first instruction on the form stated, “IMPORTANT! FOLLOW INSTRUCTIONS EXACTLY WHEN COMPLETING THIS FORM. PLEASE PRINT.” 9 CRS listed selected citations to the Washington Business Corporation Act 10 near the top of the page. The form had the disclaimer “CORPORATE RECORDS SERVICE IS NOT A GOVERNMENT AGENCY AND DOES NOT HAVE OR CONTRACT WITH ANY GOVERNMENT AGENCY TO PROVIDE THIS SERVICE.” 11 This disclaimer was surrounded by other text and *516 was located one-third of the way down from the top of the form.

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Cite This Page — Counsel Stack

Bluebook (online)
199 Wash. App. 506, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-washington-respx-app-v-the-mandatory-poster-agency-inc-washctapp-2017.