Law School Case Brief
Enslin v. Coca-Cola Co. - 136 F. Supp. 3d 654 (E.D. Pa. 2015)
The defendant bears the burden of demonstrating that a plaintiff has failed to state a claim upon which relief can be granted. The court must accept all factual allegations as true, construe the complaint in the light most favorable to the plaintiff, and determine whether, under any reasonable reading of the complaint, the plaintiff may be entitled to relief.
Plaintiff Shane K. Enslin was an employee of defendant The Coca-Cola Company ("Coke"). Over the course of several years, 55 laptop computers were stolen from Coke's premises or from premises of some of its affiliates, (collectively, "Coke"). Enslin filed a lawsuit against Coke on behalf of himself and other similarly situated employees in federal district court. Enslin claim that the stolen laptops contained his personal identification information ("PII"), as well as PII of the putative class members, which was used by identity thieves to obtain jobs and credit cards in Enslin's name. The complaint alleged 10 claims, including violation of the Driver's Privacy Protection Act, 18 U.S.C.S. § 2724; negligence; fraud; breaches of express and implied contract; and unjust enrichment. Coke filed a motion to dismiss.
Did Enslin sufficiently state claims upon which relief can be granted?
The court granted in part and denied in part Coke's motion to dismiss. The court first rejected Coke's claim to the contrary and ruled that Enslin's allegations were sufficient to establish constitutional standing in that he sufficiently alleged an injury-in-fact and a sufficient causal relationship between his injuries and Coke's alleged conduct. The court then examined each of Enslin's claims and denied the motion to dismiss for failure to state a claim as to the claims for breach of express contract, breach of implied contract, and unjust enrichment. As to the contract claims, Enslin allegations that Coke breached the parties' employment contract by not keeping his PII secure, thereby causing him damage, was sufficient to state a cause of action. Likewise, as to the unjust enrichment claim, the court ruled that Enslin stated a claim for restitution based upon Coke's breach of the parties' employment contract. The court granted Coke's motion to dismiss as to the other claims asserted by Enslin.
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