Alamo Recycling v. Anheuser Busch Inbev WorldwideAnnotate this Case
Plaintiffs Alamo Recycling, LLC and Chino Valley Recycling, LLC operated “recycling center[s]” where beverage containers sold in California may be redeemed for their “California Redemption Value.” In this action, plaintiffs sued defendant Anheuser Busch Inbev Worldwide, Inc. and other companies that sell or distribute beverages containers in California, alleging that defendants knowingly and “falsely” label beverage containers sold both inside and outside California with “CA CRV,” “California Redemption Value,” or similar labels when, in fact, under California law, only containers purchased inside California may be redeemed in California. The complaint alleged that containers sold outside California are transported into California and redeemed at recycling centers like those operated by plaintiffs, and this exposed plaintiffs to state regulatory fines and penalties, risks rendering the “California Beverage Recycling Fund” insolvent, and thereby risks the economic viability of plaintiffs’ recycling businesses. The trial court sustained defendants’ general demurrer to the complaint without leave to amend, dismissed the complaint, and entered judgment in favor of defendants. Plaintiffs appealed. The Court of Appeal concluded that the injunctive and compensatory relief plaintiffs sought could not be awarded by a California court because it would violate the “dormant” commerce clause of the federal Constitution. The Court therefore affirmed the judgment of dismissal.