Court Dismisses Claims That HFCS Beverage Is Not “All Natural”
A federal district court in New York has granted the motion for summary
judgment filed by Snapple Beverage Corp. in a case alleging that the company
misled consumers by labeling its teas and juice drinks as “All Natural” because the company’s beverages contain high-fructose corn syrup (HFCS). Weiner v. Snapple Beverage Corp., No. 07-8742 (S.D.N.Y., decided January 21,
2011). The court had previously denied plaintiffs’ motion for class certification
but determined, despite that denial, that it could decide the merits of the
summary judgment motion even though the lawsuit now failed to satisfy the
requirements of original diversity jurisdiction.
The defendant argued that the plaintiffs did not offer any evidence showing
injury from Snapple’s “All Natural” labeling, and the court agreed. Analyzing
each claim—violation of a state deceptive practices law, unjust enrichment,
and breach of express and implied warranty—the court found that the
plaintiffs failed to present reliable evidence that they paid a premium for the
company’s products.
According to the court, “Plaintiffs have provided nothing but conjecture as
to the prices they paid for Snapple and the prices of comparable beverages
available for sale at the time of their Snapple purchases. Thus, they have not
provided a sufficient ‘basis in fact’ upon which a damages award could be
based.” Similarly, the court found that they could not show “that Snapple
benefited unjustly at their expense,” or that they purchased the beverages “in
reliance on the ‘All Natural’ label.”