Mansfield v. StockX LLC

Background

Daniel Mansfield alleged that he bought shoes from StockX’s mobile app in April 2025. According to the amended complaint, StockX initially displayed a “Buy Now” price that did not include a mandatory processing fee and did not disclose that fee alongside the initial price. Mansfield continued through the purchase process instead of shopping elsewhere and ultimately paid a $12.78 processing fee.

Mansfield asserted claims under two provisions of California’s Consumers Legal Remedies Act (CLRA). One provision prohibits advertising goods with the intent not to sell them as advertised. The other prohibits displaying or offering a price that excludes mandatory fees, other than taxes and shipping costs. Mansfield sought relief for himself and two putative, or proposed, classes of StockX’s California customers.

StockX’s Arguments

StockX moved to dismiss under Federal Rules of Civil Procedure 12(b)(1) and 12(b)(6). It argued that Mansfield lacked Article III standing because he learned about the processing fee before completing the purchase and chose to pay it. StockX also argued that Mansfield had not adequately stated his CLRA claims because he lacked statutory standing, the fee-disclosure provision did not apply to bids, and he received the shoes he intended to buy at the final agreed price.

Court’s Analysis

The court held that Mansfield adequately alleged an injury for Article III standing. It reasoned that paying a fee allegedly made unlawful by the failure to disclose it at the beginning of the purchase process was a concrete economic injury. The court also held that Mansfield’s allegation that he overpaid because the initial price discouraged him from comparing prices elsewhere was sufficient at the pleading stage. Whether the delayed disclosure actually caused him to shop less or pay more was a factual issue that could not be resolved on a motion to dismiss.

The court rejected StockX’s argument that Mansfield caused his own injury by voluntarily paying the fee after learning about it. The court stated that the alleged injury resulted from StockX charging an unlawful fee that Mansfield ultimately paid, not simply from Mansfield’s voluntary payment.

The court also concluded that Mansfield adequately alleged reliance and damages under the CLRA. It measured reliance when Mansfield first saw the allegedly incomplete price, rather than only after StockX later disclosed the fee. The court found that his allegation that the initial price caused him to continue using StockX instead of shopping elsewhere was sufficient. His alleged payment of the fee and overpayment for the shoes also satisfied the CLRA’s damages requirement.

The court further held that the CLRA’s fee-disclosure provision was not limited to immediate purchases and could apply to the pricing display that customers saw before placing a bid. Finally, the court held that receiving the intended shoes did not defeat the bait-and-switch claim because Mansfield alleged that StockX initially advertised the shoes at a price it did not intend to honor.

Disposition

The court denied StockX LLC’s motion to dismiss. The order allowed Mansfield’s claims to proceed past the dismissal stage but did not decide whether StockX ultimately violated the CLRA or whether Mansfield could establish claims for the proposed classes.