Haley v. Amazon.com Services, LLC
Washington Court of Appeals
522 P.3d 80 (2022)
- Written by Brianna Pine, JD
Facts
In 2012, Jeff Haley (plaintiff) entered into a marketing agreement with Amazon.com Services, LLC (Amazon) (defendant), allowing Amazon to deduct 10 percent of Haley’s net sales receipts. The agreement contained an auto-renewal provision. Haley claimed that later that year, he opted out of the automatic renewal by submitting a form and following up with a phone call. Haley asserted that at least one Amazon representative confirmed receipt of his request. Despite this, Amazon continued making deductions. Haley sued for declaratory relief and other claims. Haley moved for summary judgment, submitting a declaration recounting the steps he took to opt out of the agreement. Amazon opposed the motion, presenting a declaration that it had no record of Haley’s opt-out communications. Finding that Haley’s declaration was self-serving and not credible, the trial court concluded that Haley did not opt out of the agreement and denied his motion. Relying on these same factual findings, the trial court later granted summary judgment in Amazon’s favor. Haley appealed.
Rule of Law
Issue
Holding and Reasoning (Dwyer, J.)
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