Ireland-Gordy v. Tile, Inc.

Background

The plaintiffs are four stalking victims who brought a putative class action against Tile, Inc., Life360 Inc., and Amazon.com, Inc. They alleged that Tile’s hidden location devices facilitated stalking, that Tile had been warned about this use, and that Tile failed to adopt safety measures that would help victims detect, search for, or disable the devices.

The court had previously granted in part Tile’s motion to compel arbitration and stayed Broad and Doe’s claims against Tile. Broad and Doe’s claims against Tile were also subject in part to a stay pending Tile’s appeal. The case otherwise proceeded on Broad and Doe’s claims against Amazon and on the Ireland-Gordys’ claims against all defendants. Tile and Amazon moved to dismiss.

Statute of Limitations

The Ireland-Gordys alleged that they learned on March 10, 2017, that a Tile tracker found in Stephanie Ireland-Gordy’s car was connected to her known stalker. The court held that this discovery gave them enough information to suspect that their injury was caused by Tile’s wrongdoing. The applicable statutes of limitations ranged from one to four years, so the deadlines had passed before the plaintiffs filed suit on August 14, 2023.

The court rejected three arguments for avoiding the limitations bar. First, it held that the continuing-violation doctrine did not apply because the complaint did not allege facts showing ongoing stalking after 2017. An alleged 2024 incident involving a broken gate was not alleged to be related to the earlier stalking or to involve a Tile tracker. Second, the court held that the discovery rule did not delay accrual until 2020 because the plaintiffs already knew of Tile’s role in 2017. Third, the court found no basis for equitable estoppel or equitable tolling. The complaint did not allege that Tile induced the plaintiffs to delay filing or that they timely pursued another legal remedy.

Disposition of the Ireland-Gordys’ Claims

The court granted Tile and Amazon’s motions to dismiss the Ireland-Gordys’ claims because the statute of limitations barred each claim. The court did not reach the defendants’ alternative grounds for dismissal. It dismissed the claims without leave to amend, finding that the proposed additional allegations would not cure the limitations defect and that further amendment would be futile.

Broad and Doe’s Claims; Stay

Because all of Broad and Doe’s claims against Tile were in arbitration or stayed pending appeal, no claims in the action would proceed against Tile at that time. The parties agreed that the stay should extend to Broad and Doe’s claims against Amazon if the Ireland-Gordys’ claims were dismissed without leave to amend. The court extended the stay to those Amazon claims because they overlap significantly with the claims against Tile.

Amazon’s motion to dismiss Broad and Doe’s claims was denied without prejudice to renewal when the stay is lifted.

Order

Judge Rita F. Lin granted Tile and Amazon’s motions to dismiss the Ireland-Gordys’ claims, dismissed those claims without leave to amend, extended the stay to Broad and Doe’s claims against Amazon, and denied without prejudice to renewal Amazon’s motion to dismiss Broad and Doe’s claims.