SIGNIFICANT CASE SUMMARIES
Washington, DC Case Summary
Corporate Accountability Lab v. Sambazon, Inc.
District of Columbia Court of Appeals
No. 23-CV-1020
Decided: August 14, 2025
Conflicts of law must be evaluated for both true and false conflicts. If a true conflict exists, the Court must determine which jurisdiction has a greater interest in applying its law by using the Restatement factors.
Background
Plaintiff is a public interest nonprofit organization. Defendant is a corporation headquartered in California, and is one of the largest United States importers of açaí. Plaintiff alleged that Defendant advertised that its açaí is “ethically sourced,” “free from child labor,” and that it “oversees every step of the products journey.” Plaintiff alleged that Defendant made fraudulent misrepresentations in violation of the District of Columbia Consumer Protection Procedures Act (“CPPA”), when it claimed to oversee every step of the products’ journey. Plaintiff also claimed that Defendant purchased fruit without investigating the producer’s use of child labor, or the existence of other dangerous working conditions.
As Defendant is headquartered in California, it argued before the D.C. Superior Court that the D.C. choice of law rules require the application of California law. Defendant claimed that the California Unfair Competition Law (“UCL”) should apply, and that under the UCL, Plaintiff lacked standing to bring a claim. The Superior Court agreed with this argument and dismissed the case. Plaintiff appealed. It argued that there is no true conflict between the District’s CPPA and the UCL and therefore, the CPPA should apply as it is the forum’s rule. Plaintiff also asserted that even if a true conflict existed, the Superior Court failed to properly apply the choice of law factors.
Holding
The Court of Appeals reversed and remanded the case. It held that the Trial Court failed to properly apply the choice of law factors. The District of Columbia applies a two-part test when analyzing choice of law issues. First, the Court must determine if a “true conflict” exists between the potentially applicable laws. A true conflict exists when the application of each law would render a different result. The Court also considers whether a “false conflict” exists, meaning that while the laws lead to different results, if only one jurisdiction’s policy would be advanced by application of its law, that jurisdiction’s law should apply. If there is a true conflict, the Court will apply a modified governmental interests analysis. This approach looks to the governmental interests underlying the policies in determining which jurisdiction’s policy would be more advanced by applying their law. In making this determination, the District Courts follow the Restatement (Second) of Conflicts of Law. That test uses four factors: (a) the place where the injury occurred, (b) the place where the conduct causing the injury occurred, (c) the domicile or place of incorporation of the parties, and (d) the place where the parties’ relationship is centered. If these factors do not reveal a greater interest for one jurisdiction, the forum law applies.
The Court of Appeals’ analysis discussed whether the Trial Court properly applied the choice of law factors from the Restatement. Addressing this argument, the Court of Appeals assumed that a true conflict existed and applied the modified interest analysis. The Court of Appeals’ analysis focused on the second factor – the place where the conduct causing the injury occurred. It held that this factor could not be yet be determined as a matter of law, since the question of where Defendant allegedly created false advertisements was never decided. This meant that the Superior Court should not have assumed that the conduct occurred in California merely because Defendant is headquartered there. Therefore, the second factor did not currently weigh in favor of either party, and on remand the Court must evaluate this factor. The Court of Appeals also held that the Superior Court misapplied the fourth factor of the test. That factor concerns the relationship of the parties. The Trial Court improperly evaluated the relationship between Defendant and the residents of D.C., rather than the relationship between the parties. Since there is no relationship between the parties, the Court of Appeals found that this factor does not apply to this case. The Court of Appeals remanded the case for further proceedings.
Questions about this case can be directed to Marcelo Perez at (202)-945-9503 or mperez@tthlaw.com.