Joaquin Lorenzo v. MillerCoors, LLC
702 F. App'x 917
| 11th Cir. | 2017Background
- Plaintiff Joaquin Lorenzo sued defendants (brewers of Coors Light) in Florida state court for unjust enrichment/false advertising, alleging he paid a premium believing Coors Light was brewed exclusively in the Rocky Mountains with Rocky Mountain spring water.
- Complaint relied on advertisements and general brand imagery (e.g., “Born in the Rockies,” “Proudly Brewed in our Rocky Mountain Tradition”) and alleged some Coors Light is brewed outside Colorado and not with Rocky Mountain spring water.
- Defendants removed to federal court and moved to dismiss: SABMiller and Molson Coors pleaded lack of personal jurisdiction and failure to state a claim; MillerCoors moved to dismiss for failure to state a claim and sought judicial notice of packaging exhibits.
- At a hearing defendants argued plaintiff lacked Article III standing because he did not allege the specific beer he purchased was brewed outside Colorado; they also argued the complaint failed to plead facts making retention of the purchase price inequitable (merits of unjust enrichment).
- The district court orally and then summarily granted the motions and allowed judicial notice, but its order did not state whether dismissal was for lack of subject-matter or personal jurisdiction or for failure to state a claim; it dismissed without prejudice and closed the case.
- Eleventh Circuit reversed and remanded, holding the district court’s order lacked necessary reasoning about jurisdictional vs. merits bases and instructing the district court to issue a reasoned decision.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Article III standing / subject-matter jurisdiction | Lorenzo alleges he was deceived and paid a premium by believing beer was Rocky Mountain–brewed and spring-water made | Defendants: Lorenzo did not allege the particular beer he bought was brewed outside Colorado, so no concrete injury => no Article III standing | Court did not resolve on merits; remanded because district court failed to state whether dismissal rested on standing (subject-matter jurisdiction) or merits |
| Personal jurisdiction | Lorenzo proceeded in Florida; implicitly argues case properly in federal court after removal | Defendants challenged personal jurisdiction; requested dismissal on that ground | Court did not state whether it accepted or rejected personal-jurisdiction arguments; remanded for a reasoned ruling |
| Failure to state a claim (false advertising / unjust enrichment) | Lorenzo alleged deceptive advertising and seeks restitution, disgorgement, and corrective advertising | Defendants: complaint lacks specific facts showing the purchased beer differed or that retention of funds was inequitable; advertisements would not lead reasonable consumer to think beer exclusively brewed in Rockies | District court’s statements could be read as merits dismissal but were unclear; Eleventh Circuit remanded for the district court to articulate whether dismissal was on merits or jurisdictional grounds |
| Judicial notice of packaging exhibit | N/A (opposed implicitly by plaintiff) | MillerCoors sought judicial notice of packaging to show labeling defeats deception claim | District court granted judicial notice without explanation; Eleventh Circuit remanded for reasoned treatment of that request |
Key Cases Cited
- Am. United Life Ins. Co. v. Martinez, 480 F.3d 1043 (11th Cir. 2007) (at motion-to-dismiss stage, court accepts plaintiff’s factual allegations as true)
- Steel Co. v. Citizens for a Better Env’t, 523 U.S. 83 (1998) (subject-matter jurisdiction is prerequisite to merits adjudication)
- Employers Reinsurance Corp. v. Bryant, 299 U.S. 374 (1937) (personal jurisdiction required before proceeding on merits)
- Bircoll v. Miami-Dade Cty., 480 F.3d 1072 (11th Cir. 2007) (appellate court may affirm on any record-supported ground, but discretion applies)
- Mosley v. Ogden Marine, Inc., 480 F.2d 1226 (5th Cir. 1973) (remand for entry of reasons where trial court’s grounds were not articulated)
- Clay v. Equifax, Inc., 762 F.2d 952 (11th Cir. 1985) (need for reasoned district-court orders to permit proper appellate review)
- McElmurray v. Consol. Gov’t of Augusta-Richmond Cty., 501 F.3d 1244 (11th Cir. 2007) (standards of review for subject-matter jurisdiction issues)
- Stubbs v. Wyndham Nassau Resort & Crystal Palace Casino, 447 F.3d 1357 (11th Cir. 2006) (personal-jurisdiction inquiry may require evidentiary development)
- Ashcroft v. Iqbal, 556 U.S. 662 (2009) (pleading standard for failure-to-state-a-claim review)