In Re: MacBook Keyboard Litigation

Background

Eleven consumers from California, Massachusetts, New York, Illinois, Florida, Washington, New Jersey, and Michigan sued Apple Inc. in a proposed class action involving MacBook and MacBook Pro laptops with butterfly keyboards. Each plaintiff alleged purchasing a laptop after seeing Apple representations that the butterfly keyboard was “more responsive,” experiencing keyboard failure within a year, and contacting Apple about the problem. They alleged that Apple did not provide effective troubleshooting or repairs, a free operable replacement laptop, or a refund. Several plaintiffs also alleged spending money on AppleCare service, insurance, or a replacement non-Apple laptop.

The plaintiffs asserted claims under California law and the laws of six other states. Under California’s Unfair Competition Law, they sought injunctive relief and restitution. They also sought unspecified injunctive relief under California’s Consumers Legal Remedies Act and equivalent state statutes.

Motion and parties’ arguments

Apple moved under Federal Rule of Civil Procedure 12(b)(6), which allows dismissal when a complaint does not state a legally sufficient claim. Apple sought dismissal of the California Unfair Competition Law claim in its entirety and dismissal of the other claims to the extent they sought equitable relief, such as restitution or an injunction.

Apple relied on the Ninth Circuit’s decision in Sonner v. Premier Nutrition Corp. The plaintiffs argued that the motion was premature, that Sonner did not apply to injunctions, and that they had adequately alleged that monetary damages were not an adequate remedy.

Court’s reasoning

The court held that the motion was not premature because the issue was whether the plaintiffs had adequately pleaded a claim for equitable relief, not whether they had to make a binding choice between remedies at an early stage.

The court read Sonner to require plaintiffs seeking equitable relief in federal court to allege that they lack an adequate remedy at law. It rejected the argument that state statutes could eliminate that requirement in federal court. The court also concluded that the requirement applied to injunctions, even though the Sonner case involved restitution rather than injunctive relief.

The court found that the complaint alleged overpayments for defective laptops and expenses incurred trying to resolve the keyboard problems. Because those injuries could be compensated with monetary damages, the court found that the plaintiffs had an adequate legal remedy. The court further found that this conclusion was clear from the face of the complaint, making amendment futile.

Disposition

The court granted Apple’s motion to dismiss. The plaintiffs’ California Unfair Competition Law claim, identified as Claim 1, was dismissed with prejudice. The remaining claims were dismissed with prejudice to the extent they sought an injunction, restitution, or other equitable relief. The order did not dismiss the remaining claims in their entirety.