Watson v. Crumbl LLC

CourtDistrict Court, E.D. California
DecidedJune 10, 2024
Docket2:23-cv-01770
StatusUnknown

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

Bluebook
Watson v. Crumbl LLC, (E.D. Cal. 2024).

Opinion

8 UNITED STATES DISTRICT COURT

9 FOR THE EASTERN DISTRICT OF CALIFORNIA

11 LISA WATSON and ANGELA KEERS, No. 2:23-cv-01770-DJC-CKD individually and on behalf of all those 12 similarly situated,

13 Plaintiffs, ORDER

14 v.

15 CRUMBL LLC, CRUMBL, IP, LLC, CRUMBL FRANCHISING, LLC, and CRUMBL 16 ENTERPRISES, LLC,

17 Defendants.

20 California law generally prohibits businesses from misrepresenting the costs of

21 their products. Here, Crumbl, which sells a variety of gourmet cookies, added a 2.95%

22 service fee to each order. While not disclosed in Crumbl’s app used to purchase 23 cookies, during checkout users could click a question mark icon on a line reading 24 “Taxes and Fees” which would send the user to a different screen that would breakout 25 the applicable taxes as well as the 2.95% Service Fee. The principal issue before the 26 Court is whether a reasonable customer would be misled by the advertised prices for 27 the cookies, which did not include the service fee. Concluding that Plaintiffs have 28 adequately alleged they would be, the Court denies Defendants’ pending Motion to 1 Dismiss (ECF No. 4) in part, but grants the Motion with respect to Plaintiffs’

2 inadequately pled claims for equitable relief.

3 BACKGROUND

4 Defendants Crumbl LLC, Crumbl IP, LLC, Crumbl Franchising, LLC, and Crumbl

5 Enterprises, LLC (collectively, “Defendants” or “Crumbl”) sell gourmet cookies and

6 beverages which customers can purchase for takeout or delivery at more than 890

7 locations throughout all fifty states. (First Am. Compl. (“FAC”) (ECF No. 17) ¶¶ 1, 20,

8 24.) Crumbl offers a weekly rotating menu of cookie flavors, and advertises their

9 menu on the Crumbl App,1 a mobile application which is available for download on a

10 customer’s individual mobile device and is also accessible on Crumbl’s website. (Id.

11 ¶¶ 3–4, 21, 25.) Customers can use the App to purchase items for pickup or delivery

12 at their local Crumbl location. (Id. ¶ 25.) Customers also use the App to complete in-

13 store purchases. (Id. ¶ 6.) Thus, all Crumbl sales are performed using the App.

14 Beginning in 2018, Crumbl began charging a 2.95% Service Fee on all

15 purchases. (Id. ¶ 7.) This Service Fee was automatically applied to every order,

16 whether the order was placed in-store or online. (Id. ¶¶ 26, 37.) When placing an

17 order in the App, customers were presented with a payment screen which displayed

18 the following line items: “Subtotal,” “Taxes & Fees,” “Tip,” and finally “TOTAL.” (Id.

19 ¶ 30.) Next to the line item “Taxes & Fees” was a small “?” icon. (Id. ¶ 31.) Only if a

20 customer clicked on the “?” icon did they see a price breakdown showing the ”Sales

21 Tax” and “Service Fee.” (Id. ¶ 32.) Customers were able to confirm their purchase on

22 the payment screen by clicking a “PAY” or “PLACE ORDER” button beneath the

23 “TOTAL.” (Id. ¶¶ 30, 35.)

24 The Service Fee was not disclosed in any signage in retail stores, nor was it

25 disclosed in any of Crumbl’s other marketing or advertising materials. (Id. ¶¶ 39–40.)

27 1 Crumbl designs, maintains, operates, and owns the App, along with all of its integrated software and 28 intellectual property. (FAC ¶ 29.) 1 Crumbl has not explained what service the fee pays for. (Id. ¶ 36.) However, Crumbl

2 ceased charging the Service Fee in May 2023. (Mot. Dismiss (ECF No. 24) at 9 n.1.)

3 Plaintiffs Lisa Watson and Angela Keers, who are California residents, allege

4 they purchased Crumbl’s products numerous times using the App on their phones,

5 with their most recent purchases occurring in March and April of 2023. (FAC ¶¶ 47,

6 48, 57, 58.) Plaintiffs allege they relied on the retail prices listed in the App and,

7 despite reviewing the menu and other information displayed, did not see any

8 disclosure of the Service Fee prior to completing their purchases. (Id. ¶¶ 50–51, 60–

9 61.) Plaintiffs further allege they believed the “Taxes & Fees” charged were local

10 and/or state sales tax. (Id. ¶¶ 52, 62.) It was only recently that Plaintiffs discovered

11 they had been charged the Service Fee on each of their purchases over the course of

12 many years. (Id. ¶¶ 52, 62.) Despite reviewing the App, Plaintiffs were unable to

13 determine why they were charged the Service Fee. (Id. ¶¶ 53, 54, 63, 64.)

14 Accordingly, Plaintiffs allege that the Service Fee was deceptive and that they were

15 harmed because there was no way for them to know about the Service Fee until after

16 they completed their purchases. (Id. ¶¶ 38, 45.)

17 Based on these allegations, Plaintiffs brought this class action under the Class

18 Action Fairness Act on August 21, 2023, asserting claims against Crumbl for

19 (1) violations of the California Consumer Law Remedies Act (“CLRA”), Cal. Civ. Code

20 §§ 1750–1784, (2) violations of California False Advertising Law (“FAL”), Cal. Bus. &

21 Prof. Code §§ 17500–17509, (3) violations of the California Unfair Competition Law

22 (“UCL”), Cal. Bus. & Prof. Code §§ 17200–17210, (4) fraudulent misrepresentation, and

23 (5) unjust enrichment/quasi-contract. (FAC ¶¶ 86–148.) Plaintiffs bring claims one

24 through three on behalf of a proposed California Class2 and claims four through five

25 on behalf of a proposed Nationwide Class,3 or alternatively, the California Class. (Id.

26 ¶¶ 75–76.) Plaintiffs seek damages, injunctive relief, and other equitable remedies.

27 2 As defined in the First Amended Complaint. (See FAC ¶ 76.) 28 3 As defined in the First Amended Complaint. (See FAC ¶ 75.) 1 Defendants brought the pending Motion to Dismiss on April 15, 2024, under

2 Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6), arguing (1) Plaintiffs lack

3 standing to seek injunctive relief because they fail to allege a risk of future harm;

4 (2) Plaintiffs are not entitled to equitable relief because they have an adequate remedy

5 at law; (3) Plaintiffs fail to state CLRA, FAL, or UCL claims because a reasonable

6 consumer would not be misled by the Service Fee and the way in which it was

7 disclosed; (4) Plaintiffs fail to adequately plead the elements of a fraudulent

8 misrepresentation claim; (5) Plaintiffs fail to state an unjust enrichment/quasi-contract

9 claim because there is no stand-alone cause of action for unjust enrichment under

10 California law and Plaintiffs fail to allege fail to allege the elements of quasi-contract;

11 and (6) Plaintiffs cannot bring claims on behalf of the Nationwide Class under

12 California law or under the laws of states other than California. (Mot. Dismiss at 2.)

13 The Court held a hearing on May 23, 2024, with Erin Ruben appearing for

14 Plaintiffs, and Jaikaran Singh and Jordan Bledsoe appearing for Defendants. The

15 matter was submitted.

16 LEGAL STANDARD

17 A party may move to dismiss a complaint for “lack of subject matter jurisdiction”

18 under Federal Rule of Civil Procedure 12(b)(1). “The party asserting federal subject

19 matter jurisdiction bears the burden of proving its existence.” Chandler v. State Farm

20 Mut. Auto. Ins. Co., 598 F.3d 1115, 1122 (9th Cir. 2010). In a “facial attack” under Rule

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