Cole v. Sephora USA Inc
Trial Court Opinion
UNITED STATES DISTRICT COURT 6 WESTERN DISTRICT OF WASHINGTON AT SEATTLE BEVERLY COLE, individually and on CASE NO. 2:25-cv-1342-JNW behalf of all others similarly situated, ORDER DENYING MOTION TO 9 Plaintiff, DISMISS 10 v. 11 SEPHORA USA INC., a foreign profit corporation, and DOES 1-20, Defendants.
On June 25, 2025, Plaintiff Beverly Cole filed this putative class action against Defendant Sephora USA, Inc. for allegedly violating Washington’s laws governing noncompetition covenants, Chapter 49.62 RCW, by “restricting, restraining, and prohibiting low-wage workers from engaging in lawful professions, trades, and businesses.” Dkt. No. 1-1 at 2. Sephora removed the case from King County Superior Court on July 17, 2025. Dkt. No. 1. Soon after, Sephora moved to dismiss Cole’s complaint for failure to state a claim on July 24, 2025. Dkt. No. 10.
On August 13, 2025, Cole filed an amended complaint. Dkt. No. 17. Because Cole filed less than 21 days after Sephora moved to dismiss, she did not need to obtain leave from the Court or Sephora to amend her complaint. Fed. R. Civ. P. 15(a)(1)(B) “A party may amend its pleading once as a matter of course no later than... 21 days after service of a motion under Rule 12(b)[.]”).
4 Generally, “an amended complaint supersedes the original complaint and renders it without legal effect.” Lacey v. Maricopa Cnty., 693 F.3d 896, 927 (9th Cir. g |) 2012). “Courts often apply this rule to motions to dismiss a complaint that has since || been superseded and deny such motions as moot.” Dahlstrom v. Life Care Centers of g ||Am., Inc., No. 2:21-CV-01465-JHC, 2022 WL 7631419, at *1 (W.D. Wash. Oct. 13, g |) 2022) (quoting Bisson v. Bank of Am., N.A., No. C12-0995-JLR, 2012 WL 5866309, 10 at *1 (W.D. Wash. Nov. 16, 2012)). Cole’s Amended Complaint supersedes the 11 original complaint and is now the operative complaint here. Sephora answered the 12 ||Amended Complaint on September 3, 2025. Dkt. No. 20.
13 Accordingly, the Court DENIES as moot Sephora’s pending motion to 14 dismiss. Dkt. No. 10.
16 Dated this 19th day of September, 2025.
18 Z Le 19 amal N. Whitehead United States District Judge
Case-law data current through December 31, 2025. Source: CourtListener bulk data.