Webb v. Injured Workers Pharmacy, LLC, No. 22-1896 (1st Cir. 2023)Annotate this Case
The First Circuit affirmed in part and reversed in part the judgment of the district court dismissing this putative action asserting various state law claims in relation to a data breach that allegedly exposed Plaintiffs' personally identifiable information (PII) and that of more than 75,000 other patients of Injured Workers Pharmacy, LLC (IWP), holding that remand was required.
Plaintiffs brought a class action complaint against IWP, a home-delivery pharmacy service registered and headquartered in Massachusetts, asserting state law claims for negligence, breach of implied contract, unjust enrichment, invasion of privacy, and breach of fiduciary duty. Plaintiffs sought to certify a class of United States residents whose PII was compromised in the data breach at issue. The district court granted IWP's motion to dismiss for lack of Article III standing. The First Circuit reversed in part, holding (1) the complaint plausibly demonstrated Plaintiffs' standing to seek damages; and (2) Plaintiffs lacked standing to pursue injunctive relief because their desired injunctions would not likely redress their alleged injuries.