Roffman v. REBBL, INC.
- Jeffrey White
- 4:22-cv-05290
- U.S. District Court · Northern District of California
- 3
In Roffman v. REBBL, INC., Judge White limited monetary relief on two California claims and dismissed the unjust-enrichment claim under the pleading rule.
Mehva Roffman and the putative classes she seeks to represent, regarding equitable monetary relief under the Unfair Competition Law and False Advertising Law and the unjust-enrichment claim; Rebbl, Inc. prevailed on its motion to dismiss.
What happened
In Roffman v. REBBL, INC., Mehva Roffman alleged that Rebbl misleadingly advertised the amount of protein in its beverages. She brought claims under California’s Consumer Legal Remedies Act, False Advertising Law, and Unfair Competition Law, plus claims for fraud and unjust enrichment, on behalf of herself and proposed classes.
Rebbl argued that Roffman had not shown that money damages were an inadequate remedy, as required for certain equitable monetary relief. The court rejected Roffman’s allegations that she might be unable to recover damages because of classwide proof requirements or the need to prove a particular state of mind. The court also found that her new allegations about her unfair-competition claim were legal conclusions rather than facts.
The court granted Rebbl’s motion to dismiss. It dismissed the Unfair Competition Law and False Advertising Law claims only insofar as they sought equitable monetary relief, and it dismissed the unjust-enrichment claim. Judge Jeffrey S. White did not state whether these dismissals were with or without prejudice.
The detailed version
- Roffman v. REBBL, INC. · No. 4:22-cv-05290
- Jeffrey White
- Dec. 4, 2024
Background
Mehva Roffman alleged that Rebbl, Inc.’s advertising of the amount of protein in its beverages was unlawful and misleading. She asserted claims under California’s Consumer Legal Remedies Act (CLRA), False Advertising Law (FAL), and Unfair Competition Law (UCL), along with common-law claims for fraud and unjust enrichment. She sought damages, restitution, and injunctive relief for herself and putative classes.
Analysis
Rebbl moved to dismiss under Federal Rule of Civil Procedure 12(b)(6), which tests whether a complaint adequately states a claim. Rebbl argued that Roffman had not adequately alleged that her legal remedies—such as damages—were inadequate, a requirement for equitable monetary relief in this type of federal case.
Roffman alleged that she and the putative class might be unable to obtain damages if the court required proof of classwide reliance and materiality beyond the objective reasonable-consumer standard, or if they could not prove the required mental state. The court again concluded that these allegations did not show that Roffman lacked an adequate legal remedy. The court explained that an inability to recover damages because claims fail on their merits does not show that the legal remedy itself is inherently inadequate.
Roffman also alleged that equitable monetary relief was needed for her UCL claims based on alleged unlawful conduct involving the failure to provide a percent daily value in the products’ Nutrition Facts panel. She argued that the California Sherman Law did not provide a direct cause of action and that her unlawful claims were distinct from her fraud-based claims. The court rejected that argument, stating that it had considered it previously, and concluded that the new allegations were legal conclusions rather than facts establishing that damages were inadequate or incomplete.
Disposition
The court granted Rebbl’s motion to dismiss. It dismissed Roffman’s UCL and FAL claims only to the extent they sought equitable monetary relief as a remedy. It also dismissed the unjust-enrichment claim. The opinion does not state whether those dismissals were with or without prejudice.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.