‘Takahashi-Mendoza v. Organic Valley’ Case Summary
Case Name: Takahashi-Mendoza v. Cooperative Regions of Organic Producer Pools d/b/a Organic Valley
Index Number: 4:22-cv-05086-JST
Court: U.S. District Court for the Northern District of California
In July 2022, PETA Foundation lawyers filed a class action lawsuit against organic dairy giant Cooperative Regions of Organic Producer Pools, doing business as Organic Valley, on behalf of a California resident who accused the company of misleading her into buying its products at premium prices by falsely claiming to provide the cows it exploits with the “highest standards” of animal care. Among other allegations, Organic Valley farmers were charged with prematurely separating newborn calves from their mothers and allowing calves to be raised in isolation, causing both significant short- and long-term harm.
The lawsuit alleged that the defendant’s conduct violated both California’s Consumers Legal Remedies Act (CLRA) and the state’s Unfair Competition Law (UCL), including because these practices don’t comport with established “highest standards” of animal care “above and beyond other standards”—including the provision of “social” settings—which the defendant touts on its labels but instead renders them false and misleading to reasonable consumers such as the plaintiff. For example, the lawsuit cited numerous studies showing that the public roundly disapproves of such false labeling, describing it as “unethical,” “inhumane,” “cruel,” and “totally unacceptable.”
Organic Valley Changes Its Labels; the Court Issues a Key Precedent
Organic Valley moved to dismiss the lawsuit, arguing that reasonable consumers wouldn’t interpret the label statements in the same manner as the plaintiff, that its label statements were nonactionable puffery, and that the plaintiff lacked standing to bring her claims and was not entitled to injunctive relief.
In May 2023, the U.S. District Court for the Northern District of California denied Organic Valley’s motion to dismiss. In a first-of-its-kind decision, Judge Jon S. Tigar held that a reasonable consumer could find Organic Valley’s carton labels “misleading because consumers could plausibly expect that such practices would not include the early separation of mother and calf.”
The opinion went on to explain that such labels represent “measurable, objective claims” and aren’t non-actionable puffery. The judge also allowed claims about Organic Valley’s alleged housing of calves by themselves in isolated hutches without vital socialization to move forward. Finally, the court held that the plaintiff’s allegations sufficiently pleaded that she had sustained an economic injury for the purposes of statutory standing under the CLRA and the UCL and that her allegations were enough at that stage for Article III standing to seek injunctive relief.
In April 2023, while the case was pending and before the court issued its decision on the motion to dismiss, Organic Valley changed its carton design. It removed claims about offering “high” or “highest” standards of animal care, that cows are raised “with love,” and that cows are “happy” or “social” as well as the word “humane.”
A year later, in September 2024, the parties mutually agreed to the lawsuit’s dismissal.