Why the CPPA matters here
D.C.’s CPPA broadly prohibits misrepresenting a material fact that has a tendency to mislead and does so “whether or not any consumer is in fact misled, deceived, or damaged.” That framework is notably plaintiff-friendly in greenwashing and ESG-marketing cases because plaintiffs need only plausibly allege that reasonable consumers could be misled by the overall net impression—including omissions and ambiguities. D.C. Law Library
The court relied on recent D.C. authority, including Earth Island Institute v. Coca-Cola, where the D.C. Court of Appeals allowed claims to proceed alleging Coca-Cola’s sustainability messaging could mislead consumers in light of plastic-waste practices. That opinion underscores that generalized “we’re sustainable” narratives can be litigated as actionable commercial claims—not immunized public-policy commentary. D.C. Courts Earth Island Institute
What NCL alleges—and why it resonates
NCL’s complaint (and the order summarizing it) points to investigations and reports tying parts of Starbucks’ supply chain to forced or child labor, wage theft, unsafe conditions, and gender-based violence—including allegations involving Brazilian coffee operations and Kenyan tea plantations. The court’s ruling doesn’t decide whether those allegations are true; it simply holds that, if true, they could render Starbucks’ “ethical sourcing” claims misleading under the CPPA.
