Case Digest: Pineda v. Williams-Sonoma Stores, Inc.

Abstract

This Case Digest summarizes the 2011 California Supreme Court case of Pineda v. Williams-Sonoma Stores, Inc. Plaintiff Pineda alleged, in part, that Williams-Sonoma violated the Song-Beverly Credit Card Act of 1971 by recording consumers' ZIP codes during credit card transactions. The Act places limitations upon the type and extent of information retailers — as well as other persons and businesses — may request of consumers using credit cards, and restricts the use of a purchaser's "personal identification information." The trial court held that a ZIP code did not constitute "personal identification information" as used in section 1747.08 of the California Civil Code. After the court of appeal affirmed, the Supreme Court of California granted review, reversed the trial court's holding, and remanded the case for further proceedings. The court held that "personal identification information," as the term is used in section 1747.08, includes a cardholder's ZIP code. As such, requesting and recording a cardholder's ZIP code, without more, violates the Credit Card Act.