Wilson v. Hewlett-Packard

To state a claim for relief under the California Consumer Legal Remedies Act and the Unfair Competition Act, a plaintiff must show that a causal connection exists between the alleged design defect and the alleged safety hazard, and that the manufacturer had knowledge of the safety hazard at the time of sale.

After using his Hewlett-Packard ("HP") laptop for two years, Cass Wilson’s ("Wilson") laptop stopped charging when plugged into a power source, rendering his computer unusable. Wilson filed a class action lawsuit against HP alleging it misrepresented and concealed a “common and uniform” design defect in the laptop that causes the laptop battery not to charge, and consequently to become too hot making the laptop a fire hazard. In a second amended complaint, Wilson and Douglas Kruschen (collectively, "Plaintiffs") further alleged that HP breached its express warranty in marketing the laptops, and violated California’s Consumer Legal Remedies Act ("CLRA") and Unfair Competition Law ("UCL"). The district court dismissed the complaint for failure to state a claim because Plaintiffs failed to identify a plausible safety hazard in the computer, or show that HP had any knowledge of the defect at the time of the sale. Plaintiffs appealed to the Ninth Circuit. California courts generally require there to be a misrepresentation about a safety issue in order to sustain a cause of action under the CLRA or UCL. The Ninth Circuit found that Plaintiffs were unable to show the required causal connection between the alleged design defect (battery not charging properly) and the alleged safety hazard (fire hazard). Further, evidence of customer complaints and other pending litigation against HP was insufficient to show that HP had knowledge of the alleged safety hazard. The Ninth Circuit affirmed the district court decision, because Plaintiffs were unable to allege a causal connection between the design defect and the safety hazard, and were unable to show that HP had any knowledge of the alleged safety hazard at the time of the sale. AFFIRMED.