A federal district court in New York has granted the motion for summary judgment filed by Snapple Beverage Corp. in a case alleging that the company misled consumers by labeling its teas and juice drinks as “All Natural” because the company’s beverages contain high-fructose corn syrup (HFCS). Weiner v. Snapple Beverage Corp., No. 07-8742 (U.S. Dist. Ct., S.D.N.Y., decided January 21, 2011). The court had previously denied plaintiffs’ motion for class certification but determined, despite that denial, that it could decide the merits of the summary judgment motion even though the lawsuit now failed to satisfy the requirements of original diversity jurisdiction.

The defendant argued that the plaintiffs did not offer any evidence showing injury from Snapple’s “All Natural” labeling, and the court agreed. Analyzing each claim—violation of a state deceptive practices law, unjust enrichment, and breach of express and implied warranty—the court found that the plaintiffs failed to present reliable evidence that they paid a premium for the company’s products.

According to the court, “Plaintiffs have provided nothing but conjecture as to the prices they paid for Snapple and the prices of comparable beverages available for sale at the time of their Snapple purchases. Thus, they have not provided a sufficient ‘basis in fact’ upon which a damages award could be based.” Similarly, the court found that they could not show “that Snapple benefited unjustly at their expense,” or that they purchased the beverages “in reliance on the ‘All Natural’ label.”