Harris v. LAZ Parking

── Harris v. LAZ Parking ── Court: Court of Appeals for the Second Circuit Date: April 30, 2026 Category: General 25-859-cv Harris v. LAZ Parking UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT SUMMARY ORDER RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL. At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 30th day of April, two thousand twenty-six. PRESENT: JOHN M. WALKER, JR., BARRINGTON D. PARKER, JOSEPH F. BIANCO, Circuit Judges. _____________________________________ AMY HARRIS, individually and on behalf of all others similarly situated, Plaintiff-Appellant, v. No. 25-859-cv LAZ PARKING LTD, LLC, LAZ KARP ASSOCIATES, LLC, Defendants-Appellees. _____________________________________ FOR PLAINTIFF-APPELLANT: DANE C. MARTIN, (Bryant T. Lamer, on the brief) Spencer Fane LLP, Kansas City, MO; William E. Bloss, Koskoff Koskoff & Bieder, P.C., Bridgeport, CT FOR DEFENDANTS-APPELLEES: JAMES T. SHEARIN, (Thomas S. Lambert, on the brief), Pullman &  Comley, LLC, Bridgeport, CT; Christopher B. Weldon, Brian J. Palmeri, Winget, Spadafora & Schwartzberg, LLP, Stamford, CT Appeal from a judgment of the United States District Court for the District of Connecticut (Nagala, J.). UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED, AND DECREED that the judgment of the district court, entered on March 10, 2025, is AFFIRMED. Plaintiff-Appellant Amy Harris appeals from a judgment of the district court dismissing her claims against Defendants-Appellees, LAZ Parking Ltd, LLC and LAZ Karp Associates, LLC (collectively, “LAZ”). LAZ is one of the nation’s largest privately-owned parking companies. On December 21, 2022, Harris parked in a LAZ lot where posted signage (the “Parking Sign”) advertised a rate of $6.00 for four hours of parking. When Harris paid for her parking session using LAZ’s online payment system, the system reflected that she would be charged a $0.37 “Service Fee,” which was not disclosed on the Parking Sign. Harris brings this action on behalf of herself and a putative class of individuals, alleging that LAZ’s imposition of the Service Fee constituted a breach of contract, a breach of LAZ’s Terms and Conditions, a violation of the Connecticut Unfair Trade Practices Act (“CUTPA”) and the Missouri Merchandising Practices Act (“MMPA”), and a civil conspiracy. The district court granted Defendants-Appellees’ motion to dismiss the Amended Complaint in its entirety, for failure to state a claim upon which relief co