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Matter of People of the State of N.Y. v. Quality King Distribs., Inc.

Citation: 2022 NY Slip Op 05010Docket: Index No. 451296/20 Appeal No. 16071-16071A Case No. 2020-04338

Court: Appellate Division of the Supreme Court of the State of New York; August 23, 2022; New York; State Appellate Court

Original Court Document: View Document

Narrative Opinion Summary

This case involves the New York Attorney General's appeal against Quality King Distributors, Inc., accused of price gouging Lysol products during the COVID-19 pandemic. The Attorney General initiated legal action under General Business Law § 396-r, claiming Quality King raised Lysol prices excessively during a market disruption. The lower court dismissed the petition, concluding there was no uniform price increase across customers, and Quality King's price adjustments were justified by increased costs. On appeal, the appellate court found that the statute prohibits any unconscionably excessive pricing, regardless of uniformity, and remanded the case for further proceedings. The court upheld the constitutionality of General Business Law § 396-r, affirming it is not vague despite lacking specific metrics for 'unconscionably excessive' pricing. The Attorney General's powers to enforce against price gouging were reaffirmed, with potential remedies including restitution and civil penalties. The court's decision emphasizes the broader interpretation of price gouging laws during emergencies and the necessity for further factual examination to determine potential violations.

Legal Issues Addressed

Attorney General's Enforcement Powers

Application: The AG is empowered to investigate and seek remedies for price gouging, including injunctive relief and civil penalties.

Reasoning: The appellate court reverses the lower court's order, dismissing the Attorney General's petition, and remands the matter for further proceedings, affirming the AG's authority to investigate and seek remedies for price gouging activities.

Constitutionality of General Business Law § 396-r

Application: The court upheld the statute's constitutionality, rejecting claims of vagueness, and affirming its application to commercial activities under a relaxed vagueness standard.

Reasoning: The court determined that the statute's language is not unconstitutionally vague, providing ordinary individuals with a reasonable understanding of prohibited conduct.

Establishing a Prima Facie Case of Price Gouging

Application: The Attorney General must demonstrate a gross disparity between the price charged and the usual price prior to the market disruption or show that the price grossly exceeded that of similar goods.

Reasoning: To establish a prima facie case of price gouging under General Business Law § 396-r, the Attorney General (AG) must provide evidence showing either a gross disparity between the price charged for consumer goods and their usual price before an abnormal market disruption, or that the price grossly exceeded that of similar goods available in the trade area.

Price Gouging under General Business Law § 396-r

Application: The statute prohibits selling essential consumer goods at unconscionably excessive prices during abnormal market disruptions.

Reasoning: Under this statute, during abnormal market disruptions affecting essential consumer goods, no entity in the distribution chain is allowed to sell these goods at unconscionably excessive prices.