Song v. Champion Petfoods USA, Inc., No. 20-3689 (8th Cir. 2022)
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The Eighth Circuit affirmed the district court's dismissal of plaintiffs' putative class action, alleging that they were misled by claims made on packages of dog food manufactured and distributed by Champion. Because plaintiffs have not challenged the district court's determinations that they lacked standing to claim that Champion misrepresented that the dog food is BPA-free, the court did not reach the merits of their related arguments.
In this case, plaintiffs were required to plausibly allege that because of defendant's affirmative misrepresentations or material omissions, their dog food packaging could deceive a reasonable consumer. The court concluded that the district court properly dismissed plaintiffs' omission-based claims because none of Champion's packaging statements are deceptive or misleading, and thus none require corrective disclosures. The court rejected plaintiffs' argument that Champion was required to disclose further information because of its special knowledge of material facts to which plaintiffs did not have access. The court stated that this duty to disclose based on special knowledge arises only in limited circumstances, which are not present in this case. Finally, the court concluded that plaintiffs' breach of warranty and unjust enrichment claims are premised on the same allegations of deception that are insufficient to support the fraud claims, and thus they fail for the same reasons.
Court Description: [Wollman, Author, with Smith, Chief Judge, and Loken, Circuit Judge] Civil case - Class Action. In a putative class action alleging defendant had falsely labeled its dog food products, the district court did not err in dismissing the plaintiffs' BPA-contamination claim for lack of standing as plaintiffs failed to allege they had purchased dog food containing BPA; to prove any of their Minnesota consumer-protection statutory claims or their common-law claims for fraudulent misrepresentation and fraudulent concealment, plaintiffs were required to plausibly allege that because of defendant's affirmative misrepresentations or or material omissions, their dog food packaging could deceive a reasonable consumer; the district court did not err in concluding that it simply was not plausible that a reasonable consumer would read the phrase "biologically appropriate' on the package and understand that defendant was also representing that it eliminated all traces of heavy metals from the food; nor did the use of the terms "fresh" and "regional" convey that fresh and regional ingredients were used exclusively; further, the package specifically stated that it used non-fresh and non-regional ingredients; the district court properly dismissed plaintiffs' omission-based claims because none of defendant's packaging statements were deceptive or misleading and none required corrective disclosures; plaintiffs' breach of warranty and unjust enrichment claims are premised on the same allegations of deception that were insufficient to support the fraud claims, and they likewise fail. [ March 07, 2022 ]
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