Jones v. Reed's

Background

Jarhonda Jones filed a proposed class action against Reed’s, Inc. concerning the labeling and marketing of Virgil’s Handcrafted Black Cherry and Virgil’s Black Cherry Zero beverages. Jones alleges that the products’ names, cherry images, and marketing suggest that the beverages contain real cherries or cherry juice, even though they allegedly contain natural flavors and malic acid instead. She also alleges that Reed’s should have disclosed that the products were artificially flavored.

Jones asserts claims under California’s Unfair Competition Law, False Advertising Law, and Consumer Legal Remedies Act, as well as a claim for unjust enrichment. She seeks damages and other relief on behalf of herself and a proposed California class. She relies on federal food-labeling rules as support for her state-law claims but does not assert a claim directly under the federal Food, Drug, and Cosmetic Act.

Motion to Transfer

Reed’s asked the court to transfer the case to the District of Connecticut under 28 U.S.C. § 1404(a), arguing that its relevant employees, documents, and corporate operations are located in or near its headquarters in Norwalk, Connecticut. Jones did not dispute that the case could have been brought in Connecticut but argued that transfer would merely shift inconvenience from Reed’s to her.

The court denied the motion to transfer. It gave some weight to Jones’s choice of California because she is a California citizen, bought one of the products in San Francisco, and brought claims under California law. The court also found that both parties have significant contacts with California. It concluded that Reed’s had not identified nonparty witnesses whose attendance could be compelled in Connecticut, and that electronic documents and physical records would not be materially harder to produce in California.

Motion to Dismiss

Reed’s moved to dismiss the First Amended Complaint in its entirety. It argued that federal law preempted Jones’s labeling theories, that the allegations did not plausibly show that a reasonable consumer would be deceived, that the fraud-based claims did not meet the heightened pleading standard under Federal Rule of Civil Procedure 9(b), that Jones lacked standing to seek an injunction, that equitable monetary relief was unavailable, and that the unjust-enrichment claim was duplicative.

The court denied Reed’s request for judicial notice of three product labels. The labels were materially different from those shown in the complaint and were obtained approximately two years after Jones’s purchase, so the court found that they did not address whether Jones adequately pleaded her claims.

Federal Preemption

The court rejected Reed’s argument that federal food-labeling law preempted Jones’s claims. Preemption means that federal law displaces a state-law requirement. The court held that Jones’s theory that the products should have used the word “flavored” after “black cherry” was consistent with the federal flavor-labeling regulations, including the rules applicable when a product depicts a fruit but contains no such ingredient.

The court also found that Jones plausibly alleged that the malic acid in the products was synthetic. Although Jones did not identify the precise form of malic acid used, she alleged in detail that both possible forms could be manufactured using petroleum-derived material. The court further held that whether the malic acid was used to impart flavor, rather than for another function, was a factual issue better addressed after the parties developed an evidentiary record. The court therefore rejected Reed’s argument that the malic-acid theory was preempted or inadequately pleaded.

Deception and Fraud Pleading

The court held that Jones plausibly alleged that a reasonable consumer could be deceived by the product labels. It found that the allegations concerning cherry representations, cherry images, and the absence of “flavored” or artificial-flavor disclosures were sufficient at the pleading stage.

The court also held that Jones’s claims under California’s Unfair Competition Law, Consumer Legal Remedies Act, and False Advertising Law that sounded in fraud satisfied Rule 9(b). That rule requires a party alleging fraud to provide specific details about who committed the alleged misconduct, what was said or omitted, when and where it occurred, and how it was misleading. The court found that Jones identified Reed’s, the product labels and representations, her purchase in 2023, and the alleged way consumers were misled.

Injunctive Relief

Reed’s argued that Jones lacked standing to seek injunctive relief because she had not alleged a real and immediate threat of future injury. Jones conceded that her First Amended Complaint did not adequately plead the requirements for injunctive relief and asked for dismissal without prejudice.

The court granted the motion to dismiss as to injunctive relief and dismissed that request without prejudice. It permitted Jones to file a Second Amended Complaint alleging, if she can, facts establishing standing to pursue an injunction. The court set April 8, 2026, as the deadline for that amendment and limited it to the defect concerning injunctive relief.

Equitable Monetary Relief and Unjust Enrichment

The court denied Reed’s request to dismiss the claim for equitable monetary relief. It concluded that the cited precedent did not impose strict pleading requirements at this stage and that a plaintiff may plead legal and equitable remedies in the alternative.

The court also denied Reed’s request to dismiss the unjust-enrichment claim. It construed that claim as a quasi-contract claim seeking restitution and found that Jones had adequately alleged deception supporting the claim.

Disposition

The Transfer Motion was denied. The Motion to Dismiss was granted in part and denied in part: Jones’s request for injunctive relief was dismissed without prejudice, while the other challenged claims were allowed to proceed.