Seidl v. Artsana USA, Inc.

Seidl v. Artsana USA, Inc.

Opinion

Defendant's Motion to Dismiss, ECF No. 17 - Granted

Joseph F. Leeson, Jr.

United States District Judge

I. INTRODUCTION

Candace Seidl purchased the KeyFit 30 car seat from Artsana USA, Inc., d/b/a Chicco, in part, because she believed it was free from chemicals known as "FRs" and "PFAS" that some car seats on the market are treated with. She thought the KeyFit 30 was chemical free because she did not see any disclosures that it had been treated with chemicals in the KeyFit 30's packaging, labeling, or ingredient list. After purchasing the KeyFit 30, however, Candace discovered that an independent third party had tested the KeyFit 30 and concluded that it does contain FRs and is likely to contain PFAS.

Though the KeyFit 30 has not caused [*2]  any health concerns for Candace or her child, she filed this putative class action lawsuit via an amended complaint, claiming that she had been harmed economically because she overpaid for the car seat believing that it was chemical free based on Chicco's omissions and misrepresentations. She points specifically to Chicco's Chemical Policy located on its website and a press release that was issued when Chicco came out with a new line of car seats. According to Candace, the Chemical Policy and press release misrepresent that the KeyFit 30 is free from FRs and PFAS. Based on Chicco's alleged misconduct, Candace brings seven different claims in her amended complaint.

Chicco filed a motion to dismiss Candace's amended complaint, making two arguments. First, it argues that Candace lacks standing because she has not alleged that she suffered an injury-in-fact. Second, it argues that Candace has failed to state a claim upon which relief can be granted for any of her seven claims.

The Court determines that Candace has alleged an injury-in-fact because she claims that she paid a price premium for the KeyFit 30 believing it was chemical free based on Chicco's alleged misconduct and that she would [*3]  not have paid as much as she did if she knew it had been treated with FRs and PFAS. However, the Court also determines that Candace has failed to state a claim for which relief can be granted for any of her claims, primarily, because Chicco is not required to disclose the chemicals it uses to treat its car seats, and because Candace did not rely on the Chemical Policy or press release when she decided to purchase the KeyFit 30.

Full case includes Shepard's, Headnotes, Legal Analytics from Lex Machina, and more.