Bohr v. Tillamook County Creamery Assn.

Summary

The court held that a private UTPA plaintiff need not always plead individual reliance to establish causation. The complaint adequately alleged theories under which purchasers could suffer loss from market-wide price inflation or from purchasing allegedly illegal products, even without observing or relying on the challenged representations. The court concluded that the lower courts improperly evaluated the ultimate viability and proof of those theories at the pleading stage and remanded for further proceedings.