Court Dismisses Consumer Fraud Claims Against Hain Celestial Group

A federal court in California has dismissed putative nationwide class claims against The Hain Celestial Group alleging that the company’s food and beverage product labels and website mislead consumers because they (i) list the ingredient “Evaporated Cane Juice” or “Organic Evaporated Cane Sugar Juice,” (ii) are falsely labeled “All Natural” or “Only Natural,” and (iii) falsely claim to have “No Trans Fat” or other nutrient content claims. Smedt v. The Hain Celestial Group, Inc., No. 12-3029 (N.D. Cal., San Jose Div., order entered August 16, 2013). The court dismissed the statutory warranty claims with prejudice on the grounds that the food products are consumables and not covered under the state and federal laws and because food and beverage labels “do not constitute express warranties against a product defect.”

The court dismissed the fraud-related claims with leave to amend within 15
days, finding that the amended complaint failed to “unambiguously specify
the particular products that have violated the particular labeling requirements,
the allegedly unlawful representations that were on the products,
and the particular statements Plaintiff allegedly relied on when making her
purchases.” The court found that the complaint “contains the same deficiencies
as did the pleadings in similar food product labeling lawsuits that were
recently dismissed by this Court. Like in those cases, here, Defendant—as well
as the Court—would have to draw its own inferences about the products at
issue and alleged mislabeling based on the equivocal assertions contained
in the Amended Complaint. Drawing such inferences about the particular
misconduct that is alleged to constitute fraud, deception, or misrepresentation
is something the heightened Rule 9 pleading standard seeks to avoid.”