Last week, a New York district judge granted juice-maker Suja Life's motion to dismiss claims alleging its juice labeled as "cold-pressed" was deceptive because the juice had been subject to an additional processing treatment after being cold-pressed.
What does it mean for juice to be "cold-pressed"? "Cold-pressed" refers to a process of extracting juice from fruits and vegetables. Suja juice, after being cold-pressed, is subjected to "cold pressure," also described as "high pressure processing," which is a preservation method. The product contains a seal on the front label as well as a brief description on the back of the bottle referencing this "cold pressure" treatment.
Plaintiff claimed she believed the juice had not been processed after being cold-pressed because of its label, its placement in the store in proximity to juices which were not subject to any treatment beyond being cold-pressed, and other factors. She did not notice the "high pressure certified" seal on the front label or review the back label description, nor did she "know what cold or high pressure was relative to processing or juice."
As a result, the Plaintiff asserted that she and other consumers would expect products described as "cold-pressed" to be "fresh," and that describing the juice as "cold-pressed" without any conspicuous disclosure of the high pressure processing step that took place, or without any visible explanation as to what "high pressure certified means," was misleading. The purported disclaimers on the labels, she argued, were "exceedingly vague or require consumers to make inferences."
Suja emphasized that cold pressing is "simply a method of extracting juice from fruits and vegetables" – and that the Plaintiff had anchored her claims around "misconceptions of what cold-pressed juice really is." While the parties do not dispute that the juices are in fact "cold-pressed," the claim, the court said, "hinges on context, the objective reasonableness of a consumer in circumstances alleged in the complaint, and common sense."
The court found that Plaintiff had failed to plausibly allege that Suja's juice product is materially misleading because a reasonable consumer would know or expect that the juice had been processed. Accordingly, the Plaintiff failed to state a plausible cause of action and Suja's motion to dismiss was granted.
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