Our notable ruling roundup aims to keep our readers up to date on recent rulings in the food & consumer packaged goods space.
Mete Karabas v. TC Heartland LLC, No.1:24-cv-02722-AMD-VMS (E.D.N.Y. – March 11, 2025): The U.S. District Court for the Eastern District of New York dismissed a putative class action alleging defendant deceptively marketed its Splenda Naturals branded Stevia Zero Calorie Sweetener as "100% Natural" when the products contain stevia leaf extract and erythritol. Plaintiff alleged violations of GBL § 349 and § 350 and New Jersey's Consumer Fraud Act (NJCFA). Claims were also asserted for breach of express warranty and intentional misrepresentation. The court concluded plaintiff failed to sufficiently allege that the product's labeling was deceptive or that it would mislead a reasonable consumer. Additionally, the court found that plaintiff failed to establish a cognizable injury under the NJCFA and did not sufficiently plead a breach of express warranty or intentional misrepresentation. Opinion available here.
Daniel Tepper, et al. v. The Quaker Oats Company, No. 1:24-cv-02055 (N.D. Ill. – March 18, 2025): The Northern District of Illinois dismissed a putative class action alleging defendant deceptively labeled and marketed its oat-based products as healthy due to their "whole grains" content despite the products containing or risking containing chlormequat, a pesticide. Plaintiffs brought claims alleging violations of the ICFA and New York consumer laws as well as unjust enrichment. The court held that Plaintiffs lacked Article III standing because they did not suffer a concrete injury as the levels of chlormequat found in the products were significantly below the tolerance level set by the EPA for imported oats. Opinion available here.
In re: Beech-Nut Nutrition Co. Baby Food Litigation, Lead Case No. 1:21-cv-00133-DNH-PJE (N.D.N.Y. – March 19, 2025): The Northern District of New York dismissed a consolidated putative class action alleging defendant sold baby food contaminated with heavy metals. Plaintiffs brought claims alleging breaches of warranties, fraudulent misrepresentation, fraud by omission, negligent misrepresentation, unjust enrichment, and deceptive and unlawful business practices. The plaintiffs argued they suffered economic harm under two theories: the benefit of the bargain and the price premium. However, the court rejected both arguments, noting plaintiffs did not allege that the challenged products were any cheaper than comparable products and failed to demonstrate an economic injury-in-fact. The court concluded that the plaintiffs did not sufficiently allege that the baby food products were unsafe or that plaintiffs had paid a higher price due to the purported misrepresentations. Opinion available here.
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