Walgreens escapes lawsuit alleging L’Oreal hair relaxer caused plaintiff’s sister to die from cancer

Walgreens hair relaxer class action overview:

• Who: U.S. District Judge Mary Rowland removed Walgreens as a defendant in a lawsuit alleging that L’Oreal’s hair relaxer products cause uterine cancer. 
• Why: Rowland determined the plaintiff failed to establish a causal connection between Walgreens’ conduct and her alleged injuries.
• Where: The L’Oreal hair relaxer cancer lawsuit was filed in Illinois federal court.
• How to get help: Other defendants remain in the hair relaxer cancer litigation. If you or a loved one developed uterine cancer after regularly using chemical hair straighteners or relaxers, you may be eligible to file or join a lawsuit.

A federal judge has removed Walgreens from a lawsuit filed by a plaintiff who claimed the retailer sold defective hair relaxer products that caused her sister’s uterine cancer-related injuries.

U.S. District Judge Mary Rowland determined plaintiff Evelyn Keaton failed to establish a causal connection between Walgreens’ conduct and her sister’s alleged injuries.

Keaton, who filed the complaint as the personal representative of her sister’s estate, claimed her sister purchased L’Oreal hair relaxer products from Walgreens, including a Soft n Beautiful Relaxer Kit for Coarse Hair.

The plaintiff argued Walgreens failed to warn consumers that the hair relaxer products it sells could cause cancer or reproductive harm.

Walgreens argued Keaton failed to plead facts sufficient to establish Article III standing and moved to dismiss her complaint in its entirety.

L’Oreal hair relaxer lawsuit failed to state a claim against Walgeeens, judge rules

Rowland determined Keaton’s allegations did not give rise to a plausible inference that Walgreens’ conduct was meaningfully connected to her sister’s claimed injuries.

The judge also found Keaton’s claim failed to state a claim for breach of implied warranty, express warranty or unjust enrichment.

“Plaintiff does not even contend Walgreens knew or should have known about any alleged cancer risks and instead concedes discovery is needed on the issue,” Rowland wrote in her ruling. “These allegations, read as a whole, do not give rise to a plausible inference that Defendant’s conduct is meaningfully connected to Plaintiff’s claimed injuries.”

Rowland ruled that Keaton’s allegations were insufficient to support a claim for unjust enrichment, as she failed to sufficiently allege how Walgreens’ retention of money from the sale of the hair relaxer products was to her detriment or how it violated fundamental principles of justice, equity and good conscience.

The judge dismissed Walgreens from the hair relaxer lawsuit but said Keaton could file a motion to amend her complaint by July 20, 2025, if she wishes to amend her claims against Walgreens.

Early this year, three women filed lawsuits against L’Oréal, claiming its hair relaxers, such as Dark and Lovely, caused their endometrial and uterine cancer.

Do you know someone who developed cancer after regularly using hair relaxer products? Learn more about the link between chemical straighteners and cancer, especially among Black women.

The plaintiff is represented by Diandra “Fu” Debrosse Zimmermann of DiCello Levitt LLP, Benjamin L. Crump of Ben Crump Law PLLC, Fidelma L. Fitzpatrick of Motley Rice LLC, Michael A. London of Douglas & London P.C. and Edward A. Wallace of Wallace Miller.

The L’Oreal hair relaxer lawsuit is Keaton v. L’Oréal USA Inc., et al., Case No. 1:24-cv-01467, in the U.S. District Court for the Northern District of Illinois, Eastern Division.

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