Complaint Against Defendant (s) Stumptown Coffee Roasters with Jury Demand (Receipt # AWAWDC-9575365) Attorney Mark Clayton Choate Added to Party Victoria Waldron Filed by Victoria Waldron. (Attachments: # 1 Summons, # 2 Civil Cover Sheet)(Choate, Mark) (Attachment 2 Replaced on 3/30/2026 Due to Malformed PDF)

5.

Plaintiff Victoria Waldron is an individual and a citizen of the State of

Washington. At all times relevant to this action, Ms. Waldron was a flight attendant aboard an Alaska Airlines flight on or about April 1, 2024.

COMPLAINT FOR PERSONAL INJURIES AND PRODUCTS LIABILITY WALDRON V. STUMPTOWN, NO. 2:26-CV-1058 CHOATE LAW FIRM, LLC 424 N. Franklin Street Juneau, Alaska 99801 Telephone: (907) 586-4490 Fax: (206) 424-9705 [email protected]

6.

Defendant Stumptown Coffee Corp. is a corporation incorporated under the laws

of the State of Delaware, with its principal place of business in Portland, Oregon. Stumptown is a specialty coffee roaster and retailer that entered into a commercial supply agreement with Alaska Airlines effective December 1, 2023, to supply a custom coffee blend for service aboard Alaska Airlines and Horizon Air flights. Stumptown designed, packaged, marketed, and sold the coffee product that was loaded and brewed on the subject flight.

7.

This Court has subject matter jurisdiction pursuant to 28 U.S.C. § 1332(a)

because the matter in controversy exceeds the sum or value of $75,000, exclusive of interest and costs, and is between citizens of different states. Plaintiff is a citizen of Washington; Defendant Stumptown Coffee Corp. is a citizen of Delaware.

8.

Venue is proper in this District pursuant to 28 U.S.C. § 1391(b)(2) because a

substantial part of the events and omissions giving rise to the claims occurred in this District, including Stumptown's commercial dealings with Alaska Airlines, which is headquartered in Seattle, Washington, and Stumptown's supply of coffee products for distribution on flights originating from Seattle-Tacoma International Airport.

9.

This Court has personal jurisdiction over Stumptown Corp. because Stumptown is

incorporated in Delaware, headquartered in Portland, Oregon and regularly transacts substantial business in the State of Washington; Stumptown entered into a commercial supply agreement with Alaska Airlines, a Washington corporation headquartered in Seattle; Stumptown supplies coffee products for distribution and consumption in Washington and on Alaska Airlines flights

COMPLAINT FOR PERSONAL INJURIES AND PRODUCTS LIABILITY WALDRON V. STUMPTOWN, NO. 2:26-CV-1058 CHOATE LAW FIRM, LLC 424 N. Franklin Street Juneau, Alaska 99801 Telephone: (907) 586-4490 Fax: (206) 424-9705 [email protected]

originating from Washington; and Stumptown has purposefully availed itself of the privilege of conducting business in this District.

A.

The Alaska Airlines-Stumptown Partnership and the Introduction of New

Packaging

10.

Prior to December 2023, Alaska Airlines served Starbucks-branded coffee aboard

its flights pursuant to a long-term partnership. In or about late 2023, Alaska Airlines terminated its relationship with Starbucks and entered into a new commercial supply agreement with Stumptown. Stumptown developed a custom coffee blend intended for service at altitude, which became available on every Alaska Airlines and Horizon Air flight beginning December 1, 2023.

11.

Stumptown conducted pre-launch testing of its coffee blend for taste

characteristics at altitude, including test brews aboard Alaska Airlines aircraft. On information and belief, however, Stumptown did not adequately design, test, or validate its coffee packaging for safe performance in commercial airline galley coffee makers under the pressurized, high-heat conditions present during commercial flight operations.

12.

Stumptown's coffee packaging was designed and produced for retail and food-

service distribution at sea level. The packaging type, material, structure, and pressure tolerance differed materially from the prior Starbucks product it replaced. Unlike the prior product, which had been used aboard Alaska Airlines flights without the same pattern of explosive failures, Stumptown's packaging was not designed, tested, or validated for compatibility with the specific onboard coffee maker equipment in Alaska Airlines' fleet.

COMPLAINT FOR PERSONAL INJURIES AND PRODUCTS LIABILITY WALDRON V. STUMPTOWN, NO. 2:26-CV-1058 CHOATE LAW FIRM, LLC 424 N. Franklin Street Juneau, Alaska 99801 Telephone: (907) 586-4490 Fax: (206) 424-9705 [email protected]

13.

Commercial aircraft cabins are pressurized to an equivalent altitude of

approximately 6,000 to 8,000 feet during flight. The reduced ambient pressure, combined with the heat cycles of commercial galley brewing equipment, creates conditions materially different from those at sea level. These conditions place unique stresses on packaged coffee products during the brewing cycle, including increased internal pack pressure and altered behavior of packaging seals and materials.

B.

The Pre-Incident Injury Pattern and Stumptown's Notice

14.

Shortly after the introduction of Stumptown coffee in December 2023, flight

attendants aboard Alaska Airlines and Horizon Air flights began reporting burn injuries caused by explosive failures of the onboard coffee makers. The failure mechanism was consistent: the coffee maker would expel scalding hot coffee, coffee grounds, and/or boiling water with explosive force during or after the brewing cycle.

15.

On or about February 20, 2024, the AFA published an official statement on its

public website identifying at least nine (9) flight attendant burn injuries caused by the explosive expulsion of scalding coffee from onboard coffee makers aboard Alaska Airlines and Horizon Air aircraft. The AFA's statement expressly noted that the recent changeover in coffee packaging was "suspected" as a contributing cause of the failures, and called for the immediate removal of the affected coffee maker units from service.

16.

On or about February 23, 2024, a flight attendant posted publicly that: after a

brew cycle, she attempted to remove the coffee pack holder and it burst, spraying hot coffee