Young Living Essential Oils
May 2, 2023
The U.S. Court of Appeals for the Second Circuit on May 2, 2023 partially vacated dismissal of a putative consumer class action against Young Living Essential Oils, LC over marketing of essential oils as "therapeutic-grade" and related health-benefit claims. In MacNaughton v. Young Living Essential Oils, the court held that "therapeutic-grade" combined with specific health, physical and medicinal-effect representations is falsifiable and not automatically nonactionable puffery.
The panel vacated dismissal of New York General Business Law deceptive-practices claims and related unjust-enrichment claims and remanded for a fact-intensive inquiry into whether reasonable consumers were misled. It affirmed dismissal of express and implied warranty claims. The plaintiff alleged she paid a premium for oils marketed with those claims.
Young Living is a Utah-based multilevel marketer of essential oils; the case returns to the Southern District of New York for further proceedings on the revived claims.