Ruling Says Pleading Flaws Doom Consumers’ Apple M1 Laptop Screen Defect Suit

An opinion issued late last week by Judge Vince Chhabria ruled in favor of Apple Inc. in the consumer suit over an alleged screen defect in certain M1 MacBook Air and MacBook Pro model computers. The Northern District of California court granted Apple’s motion to dismiss with leave to amend after it cited numerous pleading deficiencies and cautioned the plaintiffs to “carefully consider the arguments raised in the defendant’s motion to dismiss when redrafting the complaint.”

Last September’s product defect suit contends that the computers are troubled by a fragile screen that easily cracks, blacks out, shows colors, or stops working altogether. The filing pointed to purported guarantees Apple made about its screens and argued that the computers’ underperformance makes the company liable to purchasers whose hardware fell below expectation. The suit states a litany of claims for equitable relief under California consumer protection laws and also for breach of warranty, quasi-contract, and fraud-based claims.

Apple moved to dismiss the amended complaint in December 2021, arguing that even with the insight of its dismissal arguments, the plaintiffs could not overcome major pleading deficiencies. In last week’s three-page ruling, the court agreed.

Judge Chhabria opined that the fraud-based claims suffered from failure to allege reliance, specifically, “which marketing materials each plaintiff relied upon and when or whether the plaintiffs would have seen the information about the defect, had it been disclosed.”

In addition, the affirmative misrepresentation claims identified non-actionable puffery. Judge Chhabria noted that the only actionable statements the plaintiffs pleaded were not statements they allege to be false. For example, the opinion stated that the plaintiffs did not contest assertions that the laptops’ graphics are not “up to 5x faster, the biggest leap ever for MacBook Air.”

The computer buyers also failed to distinguish the relief sought in their equitable claims from those at law. “The complaint does not attempt to allege that the plaintiffs lack an adequate remedy at law nor does it allege a theory that differs in any meaningful way from the plaintiffs’ claim for damages,” Judge Chhabria wrote.

In closing, the court noted that other aspects of the complaint “leave much to be desired.” For instance, the opinion pointed to the pleading’s lack of clarity and in particular, whether the problems the plaintiffs experienced with their laptops stem from the same defect.

The plaintiffs, represented by  Bursor & Fisher P.A. and Migliaccio & Rathod LLP, have 21 days to file an amended pleading. 

Apple is represented by Weil, Gotshal & Manges LLP.