TRENTON, N.J. (Legal Newsline) - The class action plaintiff who sued over the shelf life of a Graco children's car seat lacked standing to do so, a New Jersey federal judge has ruled.
Judge Zahid Quraishi on March 28 dismissed Matthew Schmitt's lawsuit without prejudice, offering him 30 days to file an amended complaint. Schmitt sued because Graco seats are to be used for only seven to 10 years after their manufacture, and the seat he ordered was already 1.5 years old by the time he received it.
That left it at least 15% toward the end of its shelf life, Schmitt complains. But Quraishi says Schmitt failed to establish standing for a couple of reasons.
First, his purchase did not appear to have been made pursuant to a contract, so he could not have been denied the benefit of any bargain.
"Second," the judge wrote, "regardles of any lack of contract, it is undisputed that Plaintiff has not alleged any defect with the car seat, nor has he pled any facts sufficient for the Court to conclude that he would not have purchased the product at issue but for a specific misrepresentation made by Defendants.
"In that regard, wihle Plaintiff relies, in part, on cases recognizing standing on a benefit-of-the-bargain theory of economic harm, those cases are distinguishable."
Courts recognizing that theory did so in cases involving a defective product or plaintiffs who established they were induced into buying a product by a specific misrepresentation.
"Indeed, as a practical matter of commerce, the Court reasons that buyers must appreciate that certain products have a shelf life, and the manufacturing and distribution process of those products is such that some of that shelf life will inevitably be lost prior to receipt by the consumer," the ruling says.