Facts

Mars Wrigley Confectionery US, LLC, Starbucks Corp, and The Quaker Oats Company are some of the largest retailers of chocolate products in the United States. Mars claimed on the back of its Dove Dark Chocolate products that they "buy cocoa from Rainforest Alliance Certified farms, traceable from the farms into our factory," along with a seal of the Rainforest Alliance Certification. Quaker Oats claims on its Chocolate Chip Chewy Bars that it "support[s] sustainably sourced cocoa through Cocoa Horizons." Starbucks states on its Hot Cocoa Mix that it was "made with ethically sourced cocoa" and administers an internal certification program known as "COCOA." Lori Myers was a resident of Moreno Valley, California who purchased the relevant products in December 2019. On February 19, 2020, Myers, individually and on behalf of all others similarly situated, filed a putative nationwide class action against Mars Wrigley Confectionery US, LLC, Starbucks Corp, and The Quaker Oats Company for violations of California's Unfair Competition Law by misstatements on their product's labels. All three defendants moved to dismiss the claims.

PLAINTIFFS' CONTENTIONS: Plaintiffs alleged that defendants' chocolate was the product unethical child and slave labor in West Africa, including cocoa plantations in Cote d'Ivoire and Ghana that utilized some of the worst child labor conditions in the world. Plaintiffs contended that defendants induced consumers to believe its chocolate was ethically and ecologically produced and free from deforestation, poverty, or child and slave labor in West Africa by affirmative misrepresentations on defendants' product packaging. Plaintiffs argued that defendants' actions constituted unfair methods of competition and unfair and deceptive acts and practices that resulted in more sales of the goods to consumers. Further, plaintiffs maintained that plaintiff and other class members had no way of reasonably knowing that the products they purchased were not as marketed, advertised, packaged, or labeled. Finally, plaintiffs alleged that the gravity of the consequences of defendants' conduct outweighed any justification, motive, or reason, particularly considering the available legal alternatives that exists in the marketplace and that such conduct was immoral, unethical, unscrupulous, and substantially injured plaintiff and other class members.

DEFENDANTS' CONTENTIONS: Defendants alleged that no reasonable consumer would be deceived by their products' labels, and there were no affirmative statements, promises, or guarantees regarding West Africa, poverty, child labor, sustainability, farming practices, or production practices on the labels. Defendants also contended that plaintiff lacked standing to seek injunctive relief under Article III of the United States Constitution and cannot pursue claims on behalf of a nationwide class for purchases made outside of California.

Result

Defendants Quaker and Mars' motions to dismiss were granted