Clean Label Project Foundation v. Garden of Life, LLC, Civil Action No. 2020-3229

Clean Label Project Foundation (CLP), a nonprofit, sued Garden of Life in D.C. Superior Court under the D.C. Consumer Protection Procedures Act (CPPA), alleging its prenatal vitamins were contaminated and mislabeled.
Garden of Life removed the case to federal court under the Class Action Fairness Act; it then moved to dismiss for lack of Article III standing.
The U.S. District Court for the District of Columbia granted defendant’s motion and dismissed for lack of subject‑matter jurisdiction (Sept. 23, 2021).
CLP moved for reconsideration under Fed. R. Civ. P. 59(e) and 60, relying primarily on the D.C. Court of Appeals’ decision in Animal Legal Defense Fund v. Hormel Foods Corp. (ALDF), which held CPPA representational standing need not satisfy Article III injury‑in‑fact in D.C. courts.
The district court denied reconsideration, concluding ALDF does not alter Article III requirements in federal court, but granted CLP’s alternative request to remand the case to D.C. Superior Court for lack of federal jurisdiction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether ALDF is an intervening change of controlling law warranting reconsideration under Rule 59(e)/60	ALDF altered D.C. law on CPPA standing and therefore constitutes an intervening change that excuses reconsideration	ALDF is a D.C. appellate decision that cannot change Article III jurisdiction in federal court; CLP could have cited ALDF earlier	Denied: ALDF does not change federal Article III standing, and CLP failed to show extraordinary circumstances for reconsideration
Whether CLP has Article III standing to sue in federal court under CPPA representational provision (D.C. Code § 28‑3905(k)(1)(D))	CLP says ALDF demonstrates CPPA allows representational standing without an injury‑in‑fact; CLP also points to expenditures and testing it performed	Federal standing is governed by Article III; CPPA cannot supplant constitutional injury‑in‑fact requirements; CLP’s alleged expenditures do not establish concrete, particularized injury	Held: No Article III injury‑in‑fact; federal court lacks subject‑matter jurisdiction
Whether remand to D.C. Superior Court is appropriate when federal jurisdiction is lacking	CLP alternatively requested remand so it could proceed in Superior Court under ALDF	Garden of Life argued remand request was untimely or improperly raised in a reconsideration motion	Granted: Court remanded to D.C. Superior Court because it lacks subject‑matter jurisdiction and remand promotes comity and fairness

Animal Legal Defense Fund v. Hormel Foods Corp., 258 A.3d 174 (D.C. 2021) (D.C. Court of Appeals: CPPA representational standing need not meet Article III injury‑in‑fact in D.C. courts)
Spokeo, Inc. v. Robins, 578 U.S. 330 (2016) (Supreme Court: statutory violation alone does not satisfy Article III injury‑in‑fact; injury must be concrete and particularized)
Lujan v. Defenders of Wildlife, 504 U.S. 555 (1992) (Supreme Court: standing requires concrete, particularized, actual or imminent injury and traceability and redressability)
Friends of the Earth, Inc. v. Laidlaw Env’t Servs., 528 U.S. 167 (2000) (Supreme Court: injury must be actual or imminent, not conjectural or hypothetical)
Hollingsworth v. Perry, 570 U.S. 693 (2013) (Supreme Court: standing is a question of federal law and federal courts cannot rely on state standing doctrines to confer Article III jurisdiction)
Erie R.R. Co. v. Tompkins, 304 U.S. 64 (1938) (Supreme Court: federal courts apply state substantive law in diversity cases; does not permit state law to alter Article III limits)
Shaw v. Marriott Int’l, Inc., 605 F.3d 1039 (D.C. Cir. 2010) (D.C. Circuit: discussion of CPPA claims and concrete injury in certain consumer contexts)