In Re: Annie's Mac & Cheese Litigation
- Edward Chen
- 3:21-cv-02415
- U.S. District Court · Northern District of California
- 3
In re Annie’s Mac & Cheese Litigation: Judge Chen granted a request to pause the case until class-certification proceedings in Franklin are completed.
The plaintiffs and defendants in In Re: Annie's Mac & Cheese Litigation are affected because the case is paused while class-certification proceedings in the related Franklin case are completed.
What happened
In In re Annie’s Mac & Cheese Litigation, the plaintiffs and a plaintiff in a related case called Franklin agreed that this case should be paused. The defendants opposed a pause and asked the court to continue with the case, including pending motions.
The court found substantial factual and legal overlap between the two cases, which both concern Annie’s mac and cheese products and alleged phthalate disclosures. The court concluded that pausing this case could prevent inconsistent rulings and simplify the litigation, without causing undue harm to the defendants.
The court granted the plaintiffs’ request to stay this case until class-certification proceedings in Franklin are completed. Judge Edward M. Chen issued the order.
The detailed version
- In Re: Annie's Mac & Cheese Litigation · No. 3:21-cv-02415
- Edward Chen
- Oct. 26, 2021
Background
The court reviewed the parties’ joint status report. The plaintiffs in this case and the plaintiff in a related case identified as Franklin agreed that this case should be stayed, meaning paused, while the Franklin case proceeded first. The defendants disagreed and asked the court to continue litigating this case, including a motion by the Franklin plaintiff to intervene and a motion by the defendants to dismiss.
Court’s analysis
The court applied the framework from Landis v. North American Co. and related Ninth Circuit decisions. That framework requires weighing the possible harm from a stay, the hardship or unfairness a party might face, and whether a stay would simplify or complicate the issues, evidence, and legal questions. A stay should not be granted unless the other proceeding is likely to finish within a reasonable time given the urgency of the claims.
The court found that the orderly course of justice favored a stay. Both cases concern Annie’s mac and cheese products and allegations that the products contain, or may contain, phthalates without adequate disclosure. The court rejected the defendants’ characterization that the cases involved meaningfully different liability theories, finding that the Franklin case also involved omissions.
The court also found significant legal overlap. Both cases include claims under New York General Business Law sections 349 and 350, as well as claims for breach of warranty and unjust enrichment. Although the warranty claims differ and the proposed classes are not identical, the overlap could lead to inconsistent rulings, including on class certification. Rulings in Franklin could also simplify this case. The court concluded that the potential efficiency outweighed the possible prejudice to the defendants, including concerns about repeated class-certification proceedings.
Disposition
The court granted the plaintiffs’ request to stay this case pending completion of class-certification proceedings in Franklin. The order did not decide the merits of the underlying claims. Judge Edward M. Chen signed the order on October 26, 2021.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.