Almeida v. Apple, Inc.

Background

The plaintiffs alleged that displays in M1 MacBooks were vulnerable to cracking, blacking out, and other malfunctions because the aluminum housing was too thin to resist torque, meaning twisting force, and transfer it to the display. They also alleged that the display itself was unusually vulnerable to breaking and related problems. The court found that the Second Amended Complaint adequately alleged both a defect and causation.

The plaintiffs further alleged that Apple knew about the defect before the laptops were sold. The complaint described Apple’s pre-release testing, including tests involving twisting, pressure, and durability, and included more than thirty additional online user complaints. The court concluded that these allegations plausibly supported Apple’s pre-sale knowledge of the alleged defect.

Rulings

The court granted in part and denied in part Apple’s motion to dismiss.

The court dismissed with prejudice any claim based on affirmative or negligent misrepresentation because the Second Amended Complaint did not allege new or different misrepresentations from those addressed in an earlier ruling. The court also dismissed with prejudice omission-based claims relying on a partial-representation theory. The court noted that the plaintiffs could seek permission to amend if discovery later produced evidence supporting fraud-based claims.

The court denied the motion as to omission-based claims alleging that Apple’s superior knowledge created a duty to disclose the defect. The court also denied the motion as to the plaintiffs’ equitable-relief claims. It found that the allegations that the plaintiffs intended to buy Apple laptops again, including M1 MacBooks, were enough at this stage to establish standing to seek an order requiring Apple to disclose the alleged defect. The allegations also sufficiently suggested that restitution might cover the cost of a replacement laptop and repairs, while damages might be less than the full purchase price.

The court rejected Apple’s remaining arguments against the plaintiffs’ quasi-contract claim. It stated that alleging unjust enrichment as an alternative to other claims was not, by itself, a reason for dismissal. The court also found it unclear at this stage whether a valid express contract covered the same subject matter. Although Apple relied on its Limited Warranty, the court stated that the warranty’s coverage of defects in materials and workmanship might not extend to design defects. The breach-of-contract claim based on that warranty had been dropped and was not among the surviving claims.

Result and next steps

The surviving claims are the omission-based claims alleging a duty to disclose based on Apple’s superior knowledge and the claims for equitable relief. Apple’s answer was due within 14 days of the order. The court also set a case-management conference for March 24, 2023, and required a case-management statement by March 17, 2023. Judge Vince Chhabria issued the order.