Court denies Carrington Tea’s motion to dismiss injunctive relief claim over coconut oil

By Elizabeth Alt | Jun 15, 2018

SAN DIEGO (Legal Newsline) – The U.S. District Court for the Southern District of California issued an order denying Carrington Tea Co.’s motion to dismiss an amended claim for injunctive relief that claimed Carrington was misleading consumers into thinking its coconut oils were healthy.

“The prohibition of injunctive relief for 'a consumer who learns after purchasing a product that the product’s label is false' would sharply undermine the purpose of California’s consumer protection laws,” the order stated.

U.S. District Judge Michael M. Anello wrote the order on Jan. 24, stating that the ruling was guided by the 9th Circuit decision in Davidson v. Kimberly-Clark that determined a plaintiff may seek injunctive relief if he alleges that he “'faces an imminent or actual threat of future harm' due to the defendant’s false advertising.” 

Elizabeth Zemola and Matthew Beaumont filed suit against Carrington Tea over its coconut oil product in April 2017, alleging it violated California’s consumer protection laws by misleading customers into thinking the oils were a healthy alternative to other oils or butter. They sought injunctive relief, restitution, compensatory damages and court costs.

The plaintiffs amended their complaint with additional allegations following the court order dismissing their claims without prejudice in October 2017 for lack of standing to claim a relief because neither plaintiff alleged they would buy the product again in the future. 

The amended complaint stated that Beaumont would possibly buy the product in the future, but without injunctive relief, he and other consumers “will be unable to determine whether a future label bearing similar claims is valid, or whether Carrington has simply resumed misleading behavior, and thus will be unable to decide how best to spend his money.”

Carrington claimed that Beaumont’s allegations were “implausible” because it cannot reformulate coconut oil because it has only one ingredient. Carrington also states Beaumont’s allegations “contradict the crux of his theory of liability – that coconut oil products are unhealthy.”

Anello pointed out that the court is guided by the 9th Circuit ruling in deciding that “even if Beaumont is unlikely to purchase defendant’s coconut oil products in the future given his apparent beliefs regarding the healthfulness of coconut oil generally, it is not entirely implausible that he might do so and suffer harm as a result.” 

U.S. District Court for the Southern District of California case number 3:17-cv-760-MMA (KSC)

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