3:22-cv-03148-SLD-KLM # 1 Page 1 of 16
`E-FILED
` Sunday, 07 August, 2022 02:03:42 PM
` Clerk, U.S. District Court, ILCD
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF ILLINOIS
`
`SPRINGFIELD DIVISION
`
`Missy Baker, individually and on behalf of all
`others similarly situated,
`
`3:22-cv-03148
`
`Plaintiff,
`
`
`
`- against -
`
`Class Action Complaint
`
`Walmart Inc.,
`
`
`
`Defendant
`
`Jury Trial Demanded
`
`Plaintiff alleges upon information and belief, except for allegations pertaining to Plaintiff,
`
`which are based on personal knowledge:
`
`1. Walmart Inc. (“Defendant”) manufactures, labels, markets, and sells mustard
`
`promoted as sweetened with honey under the Great Value brand (“Product”).
`
`
`
`
`
`
`E-FILED
` Sunday, 07 August, 2022 02:03:42 PM
` Clerk, U.S. District Court, ILCD
`
`UNITED STATES DISTRICT COURT
`CENTRAL DISTRICT OF ILLINOIS
`
`SPRINGFIELD DIVISION
`
`Missy Baker, individually and on behalf of all
`others similarly situated,
`
`3:22-cv-03148
`
`Plaintiff,
`
`
`
`- against -
`
`Class Action Complaint
`
`Walmart Inc.,
`
`
`
`Defendant
`
`Jury Trial Demanded
`
`Plaintiff alleges upon information and belief, except for allegations pertaining to Plaintiff,
`
`which are based on personal knowledge:
`
`1. Walmart Inc. (“Defendant”) manufactures, labels, markets, and sells mustard
`
`promoted as sweetened with honey under the Great Value brand (“Product”).
`
`
`
`
`
`
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`3:22-cv-03148-SLD-KLM # 1 Page 2 of 16
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`2.
`
`The representations include “Honey Mustard,” “Made With Real Honey,” and
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`pictures of fresh mustard seeds and a honey dipper in a pool of honey.
`
`3.
`
`The representations cause consumers to expect the Product contained honey as the
`
`exclusive, primary, or significant sweetening ingredient.
`
`I. MUSTARD
`
`4. Mustard is a paste composed of ground mustard seed, salt, and vinegar, that may
`
`contain added sweeteners and spices.
`
`5.
`
`The added sweeteners can include refined sugar and honey.
`
`6. Honey mustard refers to a “basic mild, sweet mustard [with] a bit of a bite that’s
`
`mellowed and smoothed with a dollop of sweet honey.”
`
`7. Mustard and honey are typically blended in equal amounts to make honey mustard.
`
`8. Dictionaries, chefs, and commercial formulators define honey mustard as mustard
`
`blended with honey.
`
`9. While honey mustard may contain some sugar, it is primarily sweetened with honey.
`
`II. AVOIDANCE OF SUGAR
`
`10. According to the National Institutes of Health (“NIH”), there is a direct link between
`
`excess sugar consumption and obesity.1
`
`11. Doctors and nutritionists agree that excess sugar intake leads to weight gain, Type 2
`
`diabetes, dental caries, heart disease, cancer, and even dementia.2
`
`12. One food industry insider stated that “[consumer] demand for sugar reduction [cuts]
`
`across food and beverage categories,” from sodas to condiments.
`
`
`1 NIH, Sweet Stuff: How Sugars and Sweeteners Affect Your Health, October 2014.
`2 Marlene Cimons, Eating too much sugar can hurt your health, and for some it’s actually addictive,
`Washington Post December 16, 2017.
`
`2
`
`
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`3:22-cv-03148-SLD-KLM # 1 Page 3 of 16
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`13. Speakers at the International Sweetener conference affirmed that “sugar avoidance
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`was a macro trend ‘that is here to stay and will only increase.’”
`
`14. Surveys by Information Resources, Inc. (“IRI”) show that 58% of consumers avoid
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`sugar, and over 80% do so for reasons related to health and weight issues.3
`
`III. SUBSTITUTION OF SUGAR WITH HONEY
`
`15.
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`In place of sugar, consumers are substituting foods sweetened with honey.
`
`16. This is confirmed by USDA data, showing that the volume of honey has almost
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`doubled in the past 35 years, from 339 million to 603 million pounds.4
`
`17. For the first time in history in 2020, honey surpassed white sugar as America’s
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`number one choice for a sweetener.
`
`18. At least 50% of consumers are willing to pay more for foods primarily sweetened
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`with honey.
`
`19. Roughly 60% of consumers look for references to honey on a front label when
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`deciding what to buy.
`
`20. There are several reasons why consumers seek foods sweetened primarily with
`
`honey.
`
`21. First, almost three-quarters of consumers rate honey as “better-for-you” than sugar.
`
`22. Second, 93% of consumers recognize that honey is a natural sweetener, because
`
`unlike sugar, it is not heavily refined through harsh unnatural processes.
`
`23. According to the director of the National Honey Board, “Honey fits perfectly with
`
`consumers’ desire to know where their food comes from and their preference for foods that are
`
`
`3 Kieron Rooney, Yes, too much sugar is bad for our health – here’s what the science says, The
`Conversation, March 8, 2018.
`4 USDA/ERS.
`
`3
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`3:22-cv-03148-SLD-KLM # 1 Page 4 of 16
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`unprocessed,” because it “is made by bees from the nectar of flowers.”
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`24. Third, honey has a lower glycemic index than sugar, causing slower fluctuations in
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`blood sugar and insulin levels.
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`25. Refined sugars lead to rapid spikes of blood sugar, with quick spurts of energy
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`followed by sharp declines, characterized by tiredness, headaches, and difficulties in
`
`concentrating.
`
`26. Fourth, honey is sweeter than sugar, so less of it is needed to achieve the same level
`
`of sweetness.
`
`27. Fifth, unlike sugar, honey has small but significant amounts of nutrients such as
`
`vitamins, minerals, enzymes, phytonutrients and antioxidants.5
`
`28. These benefits promote immunity and aid digestion.
`
`IV. MISREPRESENTATIONS ABOUT HONEY CONTENT
`
`29. By describing the Product as honey mustard that is “Made with Real Honey” with a
`
`pictures of a dripping honey dipper and mustard seeds, consumers will expect honey is its primary
`
`or at least a significant sweetening ingredient.
`
`30. However, sugar is the primary sweetener, listed fourth in the ingredients, followed
`
`by salt, then honey, sixth.
`
`INGREDIENTS: VINEGAR, WATER,
`MUSTARD SEED,
`SUGAR, SALT,
`HONEY, SPICES, GARLIC POWDER,
`CARROT EXTRACT (COLOR), PAPRIKA.
`
`
`
`31. The Nutrition Facts discloses 1 g (or 1000 milligrams) of added sugar and 25 mg of
`
`added sodium.
`
`
`5 Brian Kennell, Healthy Food Trends Drive New Products, HuffingtonPost.com, October 1, 2015,
`updated December 6, 2017.
`
`4
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`3:22-cv-03148-SLD-KLM # 1 Page 5 of 16
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`32. Mustard seeds have a negligible, almost non-detectible amount of sodium, which
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`means the salt content is provided almost exclusively by the added salt ingredient.
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`33. One gram of salt contains 388 mg of sodium.
`
`34. For the Product to contain 25 mg of added sodium from only added salt, it would
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`contain roughly 64 mg of salt.
`
`35. This means the amount of honey by weight is less than 64 mg.
`
`36. The amount of sugar can be estimated at almost 16 times more than the amount of
`
`honey.
`
`37. Honey is not a significant sweetening ingredient in the Product based on these
`
`calculations.
`
`38. Consumers expect a product identified as honey mustard claiming to be “Made With
`
`Real Honey” with pictures of a honey dipper and mustard seeds to be sweetened mainly with honey
`
`or at a minimum, contain honey as a significant sweetening ingredient.
`
`39. Such mustards are available to consumers and are not technologically or
`
`commercially unfeasible, such as honey mustard made by True Made Foods, which lists honey as
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`its primary sweetening ingredient.
`
`INGREDIENTS Organic Vinegar, Water, Honey, Apple
`Puree Concentrate, Mustard Seed, Carrot, Butternut
`Squash, Sea Salt, Turmeric, Paprika, Spices.
`
`
`
`
`
`40. Defendant makes other representations and omissions which are false and
`
`misleading.
`
`41. The value of the Product that Plaintiff purchased was materially less than its value
`
`5
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`3:22-cv-03148-SLD-KLM # 1 Page 6 of 16
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`as represented by Defendant.
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`42. Defendant sold more of the Product and at higher prices than it would have in the
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`absence of this misconduct, resulting in additional profits at the expense of consumers.
`
`43. Plaintiff paid more for the Product based on the representations, and had she known
`
`the truth, she would not have bought it or would have paid less.
`
`44. As a result of the false and misleading representations, the Product is sold at a
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`premium price, approximately no less than $1.12 for 12 OZ (340g), excluding tax and sales, higher
`
`than similar products, represented in a non-misleading way, and higher than it would be sold for
`
`absent the misleading representations and omissions.
`
`Jurisdiction and Venue
`
`45.
`
`Jurisdiction is based on the Class Action Fairness Act of 2005 (“CAFA”). 28 U.S.C.
`
`§ 1332(d)(2).
`
`46. The aggregate amount in controversy exceeds $5 million, including any statutory
`
`damages, exclusive of interest and costs.
`
`47. Plaintiff Missy Baker is a citizen of Taylorville, Christian County, Illinois.
`
`48. Defendant Walmart Inc. is a Delaware corporation with a principal place of business
`
`in Bentonville, Benton County, Arkansas.
`
`49. The class of persons Plaintiff seeks to represent includes persons who are citizens of
`
`different states from which Defendant is a citizen.
`
`50. The members of the class Plaintiff seeks to represent are more than 100, because the
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`Product has been sold for several years, with the representations described here, in thousands of
`
`locations in the states covered by Plaintiff’s proposed classes.
`
`51. Defendant transacts business within this District through sale of the Product at its
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`6
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`3:22-cv-03148-SLD-KLM # 1 Page 7 of 16
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`over 150 stores within this State, and dozens within this District, and online, sold directly to
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`residents of this District.
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`52. Venue is in this District because Plaintiff resides in this District and the actions
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`giving rise to the claims occurred within this District.
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`53. This action is properly assigned to the Springfield Division of this District because a
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`substantial part of the events or omissions giving rise to these claims occurred in Christian County,
`
`including Plaintiff’s purchase, consumption, and/or use of the Product and awareness and/or
`
`experiences of and with the issues described here.
`
`Parties
`
`54. Plaintiff Missy Baker is a citizen of Taylorville, Illinois, Christian County.
`
`55. Defendant Walmart Inc. is a Delaware corporation with a principal place of business
`
`in Bentonville, Arkansas, Benton County.
`
`56. Walmart is an American multinational retail corporation that operates a chain of over
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`5,000 supercenters throughout the nation, selling everything from furniture to groceries.
`
`57. While Walmart sells leading national brands, it also sells a large number of products
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`under one of its private label brands, Great Value.
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`58. Private label products are made by third-party manufacturers and sold under the
`
`name of the retailer, or its sub-brands.
`
`59. Previously referred to as “generic” or “store brand,” private label products have
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`increased in quality, and often are superior to their national brand counterparts.
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`60. Products under the Great Value brand have an industry-wide reputation for quality.
`
`61.
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`In releasing products under the Great Value brand, Defendant’s foremost criteria was
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`to have high-quality products that were equal to or better than the national brands.
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`7
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`3:22-cv-03148-SLD-KLM # 1 Page 8 of 16
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`62. Defendant is able to get national brands to produce its private label items due its loyal
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`customer base and tough negotiating.
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`63. That Great Value branded products met this high bar was proven by focus groups,
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`which rated them above the name brand equivalent.
`
`64. Private label products generate higher profits for retailers because national brands
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`spend significantly more on marketing, contributing to their higher prices.
`
`65. A survey by The Nielsen Co. “found nearly three out of four American consumers
`
`believe store brands are good alternatives to national brands, and more than 60 percent consider
`
`them to be just as good.”
`
`66. Private label products under the Great Value brand benefit by their association with
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`consumers’ appreciation for the Walmart brand as a whole.
`
`67. The development of private label items is a growth area for Walmart, as they select
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`only top suppliers to develop and produce Great Value products.
`
`68. Plaintiff purchased the Product on one or more occasions within the statutes of
`
`limitations for each cause of action alleged, at Defendant’s stores, at locations such as 1530 W
`
`Springfield Rd, Taylorville, IL 62568, between May and June 2022, among other times.
`
`69. Plaintiff bought the Product because she believed and expected that the Product
`
`contained honey as the exclusive, primary, and/or most significant sweetener because that is what
`
`the representations and omissions said and implied, on the packaging and the absence of any
`
`reference or statement elsewhere on the Product.
`
`70. Plaintiff seeks to purchase mustard which contains honey as the exclusive, primary,
`
`and/or most significant sweetener.
`
`71. Plaintiff wanted more than a honey taste, but mustard sweetened with honey as an
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`8
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`3:22-cv-03148-SLD-KLM # 1 Page 9 of 16
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`ingredient.
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`72. Plaintiff relied on the words, terms coloring, descriptions, layout, placement,
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`packaging, tags, and/or images on the Product, on the labeling, statements, omissions, claims, and
`
`instructions, made by Defendant or at its directions, in digital, print and/or social media, which
`
`accompanied the Product and separately, through in-store, digital, audio, and print marketing.
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`73. Plaintiff is part of the over 50% of consumers who seek to consume more whole
`
`grains and less sugar for reasons including attention to their health, nutrition and wellness.
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`74. Plaintiff is part of the over 50% of consumers who is willing to pay, and does pay,
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`more for foods containing a predominant amount of whole grain ingredients and that are primarily
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`or exclusively sweetened with honey or contain honey as a significant sweetening ingredient.
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`75. Plaintiff bought the Product at or exceeding the above-referenced price.
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`76. Plaintiff relied on the front label representations identified here.
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`77. Plaintiff would not have purchased the Product if she knew the representations were
`
`false and misleading.
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`78. Plaintiff chose between Defendant’s Product and other similar products which were
`
`represented similarly, but which did not misrepresent their attributes and/or lower-priced products
`
`which did not make the statements and claims made by Defendant.
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`79. The Product was worth less than what Plaintiff paid and she would not have paid as
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`much absent Defendant’s false and misleading statements and omissions.
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`80. Plaintiff bought the Product at or exceeding the above-referenced price.
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`81. Plaintiff would not have purchased the Product if she knew the representations and
`
`omissions were false and misleading or would have paid less for it.
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`82. Plaintiff chose between Defendant’s Product and products represented similarly, but
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`3:22-cv-03148-SLD-KLM # 1 Page 10 of 16
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`which did not misrepresent their attributes, requirements, features, and/or components.
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`83. The Product was worth less than what Plaintiff paid and she would not have paid as
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`much absent Defendant's false and misleading statements and omissions.
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`84. Plaintiff intends to, seeks to, and will purchase the Product again when she can do so
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`with the assurance the Product's representations are consistent with its attributes and/or
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`composition.
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`85. Plaintiff is unable to rely on the labeling and representations not only of this Product,
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`but other similar honey mustard condiments, because she is unsure whether those representations
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`are truthful.
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`Class Allegations
`
`86. Plaintiff seeks certification under Fed. R. Civ. P. 23 of the following classes:
`
`Illinois Class: All persons in the State of Illinois who
`purchased
`the Product during
`the statutes of
`limitations for each cause of action alleged; and
`
`Consumer Fraud Multi-State Class: All persons in
`the States of North Dakota, West Virginia, Virginia,
`North Carolina, Kentucky, New Mexico, Oklahoma,
`Utah, Nebraska, South Carolina, Kansas, and
`Wyoming who purchased the Product during the
`statutes of limitations for each cause of action
`alleged.
`
`87. Common questions of issues, law, and fact predominate and include whether
`
`Defendant’s representations were and are misleading and if Plaintiff and class members are entitled
`
`to damages.
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`88. Plaintiff's claims and basis for relief are typical to other members because all were
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`subjected to the same unfair, misleading, and deceptive representations, omissions, and actions.
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`89. Plaintiff is an adequate representative because her interests do not conflict with other
`
`members.
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`10
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`3:22-cv-03148-SLD-KLM # 1 Page 11 of 16
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`90. No individual inquiry is necessary since the focus is only on Defendant’s practices
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`and the class is definable and ascertainable.
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`91.
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`Individual actions would risk inconsistent results, be repetitive and are impractical
`
`to justify, as the claims are modest relative to the scope of the harm.
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`92. Plaintiff's counsel is competent and experienced in complex class action litigation
`
`and intends to protect class members’ interests adequately and fairly.
`
`93. Plaintiff seeks class-wide injunctive relief because the practices continue.
`
`Illinois Consumer Fraud and Deceptive Business Practices Act
`(“ICFA”), 815 ILCS 505/1, et seq.
`
`(Consumer Protection Statute)
`
`94. Plaintiff incorporates by reference all preceding paragraphs.
`
`95. Plaintiff believed the Product contained honey as the exclusive, primary, or
`
`significant sweetening ingredient.
`
`96. Plaintiff relied on the front label representations about honey to believe the Product
`
`contained honey as the exclusive, primary, or significant sweetening ingredient.
`
`97. Plaintiff paid more for the Product based on these representations, and she would not
`
`have purchased it or paid as much if the true facts had been known, suffering damages.
`
` Violation of State Consumer Fraud Acts
`
`(Consumer Fraud Multi-State Class)
`
`98. The Consumer Fraud Acts of the States in the Consumer Fraud Multi-State Class are
`
`similar to the consumer protection statute invoked by Plaintiff and prohibit the use of unfair or
`
`deceptive business practices in the conduct of commerce.
`
`99. The members of the Consumer Fraud Multi-State Class reserve their rights to assert
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`11
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`3:22-cv-03148-SLD-KLM # 1 Page 12 of 16
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`their consumer protection claims under the Consumer Fraud Acts of the States they represent
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`and/or the consumer protection statute invoked by Plaintiff.
`
`100. Defendant intended that members of the Consumer Fraud Multi-State Class would
`
`rely upon its deceptive conduct.
`
`101. As a result of Defendant’s use of unfair or deceptive acts, the Consumer Fraud Multi-
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`State Class sustained damages.
`
`Breaches of Express Warranty,
`Implied Warranty of Merchantability/Fitness for a Particular Purpose and
`Magnuson Moss Warranty Act, 15 U.S.C. §§ 2301, et seq.
`
`102. The Product was manufactured, identified, distributed, marketed, and sold by
`
`Defendant and expressly and impliedly warranted to Plaintiff that it contained honey as the
`
`exclusive, primary, or significant sweetening ingredient.
`
`103. Defendant directly marketed the Product to Plaintiff and consumers through its
`
`advertisements and marketing, through various forms of media, on the packaging, in print
`
`circulars, direct mail, product descriptions, and targeted digital advertising.
`
`104. Defendant knew the product attributes that potential customers like Plaintiff were
`
`seeking and developed its marketing and labeling to directly meet those needs and desires.
`
`105. Defendant’s representations about the Product were conveyed in writing and
`
`promised it would be defect-free, and Plaintiff understood this meant that it contained honey as
`
`the exclusive, primary, or significant sweetening ingredient.
`
`106. Defendant’s representations affirmed and promised that the Product contained honey
`
`as the exclusive, primary, or significant sweetening ingredient.
`
`107. Defendant described the Product so Plaintiff and consumers believed it contained
`
`honey as the exclusive, primary, or significant sweetening ingredient, which became part of the
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`12
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`3:22-cv-03148-SLD-KLM # 1 Page 13 of 16
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`basis of the bargain that it would conform to its affirmations and promises.
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`108. Defendant had a duty to disclose and/or provide non-deceptive descriptions and
`
`marketing of the Product.
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`109. This duty is based on Defendant’s outsized role in the market for this type of Product,
`
`a trusted company, known for its high-quality products, honestly marketed to consumers.
`
`110. Plaintiff recently became aware of Defendant’s breaches of the Product’s warranties.
`
`111. Plaintiff provides notice to Defendant, its agents, representatives, retailers, and their
`
`employees that it breached the express and implied warranties associated with the Product.
`
`112. Defendant received notice and should have been aware of these issues due to
`
`complaints by third-parties, including regulators, competitors, and consumers, to its main offices,
`
`and by consumers through online forums.
`
`113. The Product did not conform to its affirmations of fact and promises due to
`
`Defendant’s actions.
`
`114. The Product was not merchantable because it was not fit to pass in the trade as
`
`advertised, not fit for the ordinary purpose for which it was intended and did not conform to the
`
`promises or affirmations of fact made on the packaging, container, or label, because it was
`
`marketed as if it contained honey as the exclusive, primary, or significant sweetening ingredient.
`
`115. The Product was not merchantable because Defendant had reason to know the
`
`particular purpose for which the Product was bought by Plaintiff, because she expected it contained
`
`honey as the exclusive, primary, or significant sweetening ingredient, and she relied on
`
`Defendant’s skill and judgment to select or furnish such a suitable product.
`
`116. Plaintiff and class members would not have purchased the Product or paid as much
`
`if the true facts had been known, suffering damages.
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`13
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`Negligent Misrepresentation
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`117. Defendant had a duty to truthfully represent the Product, which it breached.
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`118. This duty was non-delegable, and based on Defendant’s position, holding itself out
`
`as having special knowledge and experience in this area, a trusted company known for high-quality
`
`products, honestly marketed to consumers.
`
`119. Defendant’s representations and omissions regarding the Product went beyond the
`
`specific representations on the packaging, as they incorporated the extra-labeling promises and
`
`commitments to quality, transparency and putting customers first, that it has been known for.
`
`120. These promises were outside of the standard representations that other companies
`
`may make in a standard arms-length, retail context.
`
`121. The representations took advantage of consumers’ cognitive shortcuts made at the
`
`point-of-sale and their trust in Defendant.
`
`122. Plaintiff and class members reasonably and justifiably relied on these negligent
`
`misrepresentations and omissions, which served to induce and did induce, their purchase of the
`
`Product.
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`123. Plaintiff and class members would not have purchased the Product or paid as much
`
`if the true facts had been known, suffering damages.
`
`Fraud
`
`124. Defendant misrepresented and/or omitted the attributes and qualities of the Product,
`
`that it contained honey as the exclusive, primary, or significant sweetening ingredient.
`
`125. Defendant possesses specialized knowledge regarding the importance of the source
`
`of a food’s sweetener to consumers based on internal and external research and reports.
`
`126. The records Defendant is required to maintain provided it with actual and/or
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`3:22-cv-03148-SLD-KLM # 1 Page 15 of 16
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`constructive knowledge of the falsity and/or inaccuracy of the representations.
`
`127. The records Defendant is required to maintain provided it with actual and/or
`
`constructive knowledge of the falsity and/or inaccuracy of the representations.
`
`Unjust Enrichment
`
`128. Defendant obtained benefits and monies because the Product was not as represented
`
`and expected, to the detriment and impoverishment of Plaintiff and class members, who seek
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`restitution and disgorgement of inequitably obtained profits.
`
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`
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`Jury Demand and Prayer for Relief
`
`Plaintiff demands a jury trial on all issues.
`
` WHEREFORE, Plaintiff prays for judgment:
`
`1. Declaring this a proper class action, certifying Plaintiff as representative and the
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`undersigned as counsel for the class;
`
`2. Entering preliminary and permanent injunctive relief by directing Defendant to correct the
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`challenged practices to comply with the law;
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`3. Injunctive relief to remove, correct and/or refrain from the challenged practices and
`
`representations, and restitution and disgorgement for members of the class pursuant to the
`
`applicable laws;
`
`4. Awarding monetary damages, statutory and/or punitive damages pursuant to any statutory
`
`claims and interest pursuant to the common law and other statutory claims;
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`5. Awarding costs and expenses, including reasonable fees for Plaintiff's attorneys and
`
`experts; and
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`6. Other and further relief as the Court deems just and proper.
`
`Dated:
`
`August 7, 2022
`
`
`
`
`
`
`
`Respectfully submitted,
`
`
`15
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`3:22-cv-03148-SLD-KLM # 1 Page 16 of 16
`
`/s/Spencer Sheehan
`Sheehan & Associates, P.C.
`Spencer Sheehan
`60 Cuttermill Rd Ste 412
`Great Neck NY 11021
`Tel: (516) 268-7080
`spencer@spencersheehan.com
`
`
`
`16
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