Saedi v. Coterie Baby, Inc.
- Denise Cote
- 1:24-cv-03893
- U.S. District Court · Southern District of New York
- 17
Saedi v. Coterie Baby, Judge Cote dismissed Saedi’s class action because she did not plausibly allege standing.
Roz Saedi’s individual claims and the proposed class claims were dismissed without prejudice for lack of Article III standing; Coterie Baby, Inc.’s motion to dismiss was granted, and the court did not decide the merits of the claims.
What happened
In Saedi v. Coterie Baby, Inc., Roz Saedi alleged that Coterie advertised its diapers as free of per- and polyfluoroalkyl substances, or PFAS, even though testing found PFAS in one diaper. She said she paid more because she believed the diapers were PFAS-free and brought claims for herself and a proposed class.
Coterie asked the court to dismiss the case, arguing that Saedi lacked the constitutional injury required to sue and had not stated valid claims. The court focused on whether Saedi plausibly alleged that the diapers she bought contained PFAS and that she therefore paid a price premium.
Judge Denise Cote granted Coterie’s motion to dismiss for lack of standing and dismissed the amended complaint without prejudice. The court held that general allegations about PFAS in the environment and testing of one diaper Saedi did not purchase did not plausibly show that the diapers she received were contaminated. The court did not decide whether her underlying claims were legally valid.
The detailed version
- Saedi v. Coterie Baby, Inc. · No. 1:24-cv-03893
- Denise Cote
- Oct. 3, 2024
Background
Roz Saedi sued Coterie Baby, Inc., individually and on behalf of a proposed class. The complaint alleged that Coterie marketed its diapers as “Free From PFAS” and “PFAS-Free,” while an independent laboratory test of one Coterie diaper identified multiple PFAS chemicals. Saedi alleged that she paid a premium for Coterie’s diapers because she believed they were free from PFAS and other harmful chemicals.
The first amended complaint asserted six counts: breach of express warranty, unjust enrichment, violations of several state consumer-protection statutes, and violations of California’s Consumer Legal Remedies Act, False Advertising Law, and Unfair Competition Law. Saedi sought damages and injunctive and declaratory relief for herself and proposed nationwide and state-based classes.
Motion and standing requirement
Coterie moved to dismiss under Federal Rule of Civil Procedure 12(b)(1), which concerns the court’s subject-matter jurisdiction, and Rule 12(b)(6), which concerns whether a complaint states a legally sufficient claim. Coterie argued that Saedi lacked Article III standing and had failed to state a claim. The court ruled on the Rule 12(b)(1) issue and granted that motion.
To establish Article III standing, a plaintiff must show a concrete and particularized injury, a connection between that injury and the defendant’s conduct, and a likelihood that a favorable decision would remedy the injury. In a proposed class action, the named plaintiff must show that she personally was injured; alleged injuries to unidentified class members are not enough.
The court recognized that paying too much for a product can be a concrete financial injury. Saedi’s theory was that she paid a price premium for diapers advertised as PFAS-free, but that the diapers in fact contained PFAS. At the pleading stage, the court generally accepts factual allegations as true and draws reasonable inferences in the plaintiff’s favor. It need not, however, accept legal conclusions, unsupported assertions, or inferences that are not plausibly supported by the alleged facts.
Why the court found standing inadequately pleaded
The court held that Saedi had not plausibly alleged that she purchased a Coterie diaper containing PFAS. The simplest way to plead that injury, the court explained, would have been to allege that Saedi had tested one of the diapers she received in March 2024 and that the test found PFAS. She did not make that allegation.
Instead, Saedi relied on general allegations that PFAS are widespread in the environment and on the independent test of a single Coterie diaper that she did not purchase. The court found that these allegations did not plausibly show that Coterie’s diapers were systematically or routinely contaminated or that one of the diapers Saedi received contained PFAS.
The court also examined a literature review cited in the complaint. It concluded that the study did not support Saedi’s allegation that PFAS were widely present in dust in commercial buildings or manufacturing facilities. The study discussed indoor spaces such as homes, daycares, and offices, identified various possible sources of PFAS, and stated that there was insufficient data to determine which sources were dominant. The court therefore did not accept the complaint’s broader inference that it was essentially impossible to produce a PFAS-free diaper.
Finally, the court found that Saedi had not meaningfully connected the tested diaper to the diapers she purchased. Her allegation, made on “information and belief,” that the tested diaper was manufactured similarly and in the same facilities as her diapers was conclusory. The court stated that those words do not make an unsupported allegation plausible unless the belief is based on factual information or on facts especially within the defendant’s control.
Disposition
The court granted the July 26, 2024 motion to dismiss for lack of standing. It dismissed the first amended complaint without prejudice and directed the Clerk of Court to close the case. Because the court dismissed the action for lack of Article III standing, it did not address Coterie’s other standing arguments or whether Saedi had stated valid claims under the various warranty, unjust-enrichment, and consumer-protection theories. Judge Denise Cote’s ruling was therefore a jurisdictional dismissal rather than a decision on whether Coterie’s PFAS advertising violated those laws.
Read the full 17-page opinion on CourtListener, the free public archive maintained by the Free Law Project.