Guzman v. Polaris Industries

Under Somner v. Premier Nutrition Corp., 971 F.3d 834, 837 (9th Cir. 2020), a plaintiff may only seek an equitable remedy under the UCL and CLRA if they lack an adequate legal remedy.

Jeremy Albright and Paul Guzman filed a class action suit against Polaris Industries, alleging the labels on Polaris vehicles that stated the rollover protective cages complied with Occupational Safety and Health Administration standards were false and misleading and that they had relied on these labels when purchasing a Polaris vehicle. This action was brought under the California Unfair Competition Law (UCL), California Consumers Legal Remedies Act (CLRA), and the California False Advertising Act (FAL). Albright appealed the district court’s grant of summary judgment in favor of Polaris, arguing that in granting summary judgment, his UCL claim had been disposed with prejudice which precluded him from refiling the action in state court. Under Somner v. Premier Nutrition Corp., 971 F.3d 834, 837 (9th Cir. 2020), a plaintiff may only seek an equitable remedy under the UCL and CLRA if they lack an adequate legal remedy. The Court found that had Albright timely pursued his CLRA claim he would have had an adequate legal remedy, and his failure to have timely pursued this does not provide him equitable jurisdiction on a federal court to hear his UCL claim. United States v. Elias, 921 F.2d 870, 874-74 (9th Cir. 1990). Because the district court lacked equitable jurisdiction, they should have dismissed the claim without prejudice rather than granting Polaris Industries summary judgment which prevented Albright from refiling in state court. Reversed and Remanded.