Beasley v. Lucky Stores, Inc.

Background

Mark Beasley brought a putative class action as a purchaser and consumer of Coffee-mate products. He alleged that, during the class period, Coffee-mate products other than the Natural Bliss line contained partially hydrogenated oil, which he described as an artificial source of trans fat. He also alleged that the products carried unauthorized nutrient-content claims, including “0g Trans Fat” and “IT’S GOOD TO KNOW: 0g TRANS FAT/SERV,” as part of an intentional campaign to market Coffee-mate as healthful and free of trans fat.

Beasley asserted claims under California’s Unfair Competition Law, California’s False Advertising Law, for breach of express warranty, and under the California Consumer Legal Remedies Act. He brought the claims individually and for a proposed class of California citizens who purchased in California, between January 1, 2010, and December 31, 2014, Coffee-mate containing both the “0g Trans Fat” claim and partially hydrogenated oil.

Motion and arguments

The defendants moved for summary judgment under Rule 56 of the Federal Rules of Civil Procedure on the limited issue of whether Beasley’s claims were barred by the applicable statutes of limitation. The longest limitations period at issue was four years. The defendants argued that Beasley was not entitled to delayed accrual of his claims because he had known that trans fat was bad, knew that packaged foods had ingredient lists, sought to avoid trans fat during the class period, and knew that consumers could check ingredient lists for partially hydrogenated oil.

Beasley relied on deposition errata and a declaration stating that he did not know until 2017 that partially hydrogenated oil was the source of artificial trans fat in food. The defendants challenged those later statements because they were made after the summary-judgment motion was filed and contradicted deposition testimony. The court stated that even if those changes were disregarded, a factual dispute about when the claims accrued remained.

Court’s analysis

Under California’s discovery rule, a claim generally accrues when the plaintiff discovers, or has reason to discover, the claim. The court explained that when a plaintiff reasonably should have discovered the relevant facts is generally a question of fact, and summary judgment is proper on that issue only when the evidence supports one reasonable conclusion. A plaintiff has reason to discover a claim when the plaintiff at least suspects a factual basis for it or suspects that someone did something wrong, even without knowing the legal theory.

The court acknowledged that the Coffee-mate ingredient lists identified partially hydrogenated oil. But it also noted that the packaging stated “0g Trans Fat,” and that the Nutrition Facts panel stated “Trans Fat/Grasa Trans 0g.” The court found a triable issue—a factual dispute that must be resolved at trial—about whether Beasley, when faced with multiple clear statements that Coffee-mate contained no trans fat, should have investigated the ingredient list. Because the evidence supported conflicting inferences, summary judgment was improper.

Rulings

Judge Maxine M. Chesney denied defendants’ motion for summary judgment. The ruling left unresolved whether Beasley’s claims were time-barred; it did not decide the ultimate merits of the alleged labeling violations.

The court also denied Beasley’s request that it enter summary judgment against defendants on whether “0g Trans Fat” was an unlawful nutrient-content claim. The court noted that it had previously denied Beasley leave to file a cross-motion for summary judgment on that issue.