Rutter v. Bright Horizons Family Solutions Inc, 2:23-cv-00233

Chelsea Rutter, a former teacher at Bright Horizons in Seattle, sued Bright Horizons in state court over a "placement fee provision" in the company’s enrollment contract with client families.
The provision requires families to pay Bright Horizons $5,000 if they hire a former Bright Horizons staff member within six months of that employee’s departure.
Rutter alleged this fee provision limited her ability to be hired as a nanny by client families and suppressed her wages by reducing her bargaining power.
The lawsuit challenged the fee under Washington’s Noncompetition Covenants statute and the Consumer Protection Act (CPA), seeking to represent a class.
Bright Horizons removed the case to federal court and moved to dismiss for failure to state a claim.
The court raised and addressed the issue of whether Rutter had Article III standing to bring her claims in federal court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Standing (Injury-in-Fact)	Rutter was "restrained" from job opportunities and wage negotiation by the placement fee provision.	No concrete injury alleged; only hypothetical restraints.	Rutter did not allege a concrete, non-hypothetical injury; lacks standing.
Applicability of Noncompetition Statute	Provision is an unenforceable noncompetition clause, even if not in employment contract.	Statute doesn't apply because the provision is only in the family enrollment contract, not Rutter’s employment agreement.	Court declined to reach the issue due to lack of standing.
Injury under CPA	Placement fee provision was deceptive and suppressed Rutter’s wages.	No specific factual allegation of wage suppression or job loss traceable to the provision.	No facts alleged to show wage suppression or quantifiable injury; no standing.
Remedy for Lack of Standing	Federal court should consider the case and dismiss.	Case must be remanded if no subject-matter jurisdiction.	Remanded case to state court for lack of federal jurisdiction.

Warth v. Seldin, 422 U.S. 490 (standing is a threshold question for federal court jurisdiction)
Spokeo, Inc. v. Robins, 578 U.S. 330 (Article III standing requires a concrete injury)
Davis v. Fed. Election Comm’n, 554 U.S. 724 (standing is required for every claim and form of relief sought)
Arbaugh v. Y&H Corp., 546 U.S. 500 (federal courts must ensure subject-matter jurisdiction on their own motion)
TransUnion LLC v. Ramirez, 594 U.S. 413 (class action members must have suffered concrete injury for standing)