Joanne Magliocca v. United Healthcare Services, Inc.

Published by Crandall Consulting · Informational litigation intelligence · Last substantive update: October 1, 2026

Docket / citation: 2:25-cv-03388 · Filed: 2026-08-19

Summary

The U.S. District Court for the Eastern District of California granted UnitedHealthcare’s motion to dismiss the First Amended Complaint and dismissed the action with prejudice on August 19, 2026, finding plaintiff lacked Article III standing. The court held the alleged website tracking (cookies, session recorder, canvas fingerprinting, etc.) and resulting targeted ads did not allege a sufficiently concrete privacy injury; it declined to reach the merits and refused further amendment.

Litigation Status

Status, direction, and weight describe how tracked public sources characterize this matter as of our last review — they are informational classifications, not legal assessments.

Procedural Posture

Plaintiff filed a putative class action in state court, defendant removed to federal court and moved to dismiss; the court previously dismissed the original complaint for lack of standing with leave to amend; plaintiff filed a First Amended Complaint; defendant moved to dismiss the FAC; the court again found no Article III standing and dismissed the FAC with prejudice and denied further amendment.

Reported Holding

The court granted defendant’s motion to dismiss the First Amended Complaint and dismissed the action with prejudice because plaintiff failed to allege a concrete, Article III injury sufficient for standing; the court declined to reach the merits and denied further amendment.

What the Court Decided

The court held that plaintiff’s new factual allegations about website third-party tracking (including cookies, canvas fingerprinting, and a session recorder) were insufficient to allege a concrete invasion-of-privacy injury and therefore plaintiff lacked Article III standing; the First Amended Complaint was dismissed with prejudice.

What the Court Did Not Decide

The court did not reach or decide the merits of plaintiff’s CIPA, ECPA, CDAFA, or California constitutional claims because it found it lacked jurisdiction due to lack of standing.

Significance

Generally viewed as defense-favorable. Characterizations of significance describe how the matter has generally been discussed in tracked public sources; individual holdings are often narrow, procedural, or fact-specific, and this page does not state or imply broader holdings than the sources support.

What This Page Does and Does Not Say

This page reports what our tracked public sources say about this matter — including, where identified, the procedural posture (for example, a ruling on a motion to dismiss is not a final merits decision). It does not report legal conclusions beyond those sources, does not predict outcomes, and does not constitute legal advice.

Technologies at Issue

• cookies
• canvas fingerprinting
• device fingerprinting
• session recording/session replay
• persistent identifiers

Third parties named or identified in tracked sources: Google Ads/DoubleClick, Adobe / Adobe Audience Manager, Qualtrics, SessionCam Ltd., Shape Security, Datadog, LivePerson, Branch / App.link.

Statutes Invoked

• California Invasion of Privacy Act (CIPA); Electronic Communications Privacy Act (ECPA); California Computer Data Access and Fraud Act (CDAFA); California Constitution (privacy claim) — all-party consent · private right of action

Claims Asserted

Claims identified in tracked public sources; pleadings may include additional or amended claims.

• California Invasion of Privacy Act (CIPA)
• Electronic Communications Privacy Act (ECPA)
• California Computer Data Access and Fraud Act (CDAFA)
• California Constitution — invasion of privacy

What This Matter May Mean for Website Operators

California Invasion of Privacy Act (CIPA) is an all-party consent statute with a private right of action. Consent standard and private enforceability are the structural features that most shape where website tracking claims are filed and how they are valued.

For operators using similar technologies, the recurring factual questions in matters like this one are when session recording begins relative to consent and whether input masking covers every field. Our scanner tests these behaviors empirically.

The reported outcome direction at the standing stage reflects how tracked sources characterize the ruling; such rulings are often narrow, posture-specific, and fact-bound rather than broad statements of law.

Detection of a similar technology on a website is an informational risk indicator, not a legal conclusion, and nothing in this section is legal advice.

Related Intelligence

Sources

• Case 2:25-cv-03388-WBS-SCR — Document 34 (Order) — govinfo (U.S. Courts) · Tier B (Authoritative secondary) · 2026-08-19

About This Page

Publisher: Inspection-Ready Institute, Inc. (DBA Crandall Consulting), an independent website compliance and risk consultancy. We are not a law firm and nothing on this page is legal advice.

How this content is produced: Facts are extracted from publicly available sources — court and government materials, recognized legal press, professional analysis, and industry reports — by our litigation intelligence engine, stored with full source provenance, and rendered from the database. Risk guidelines are computed by a deterministic formula, never by an AI model directly. See the full methodology.

Limitations: Counts labeled "Tracked" reflect matters identified in our source set and are not official court statistics. We report what courts decided and did not decide; we do not predict outcomes.

Corrections: If you believe anything on this page is inaccurate, contact us via the contact page and we will review the underlying sources promptly.