North Carolina Court Dismisses Benzene Dry Shampoo Claims, Cites Lack of Evidence

CHARLOTTE, N.C. –– A North Carolina federal court has dismissed benzene dry shampoo claims asserted against Unilever, finding that the recall alone is not evidence of exposure to contaminated products.

In the Aug. 28 order, the U.S District Court for the Western District of North Carolina concluded that the plaintiff “does not allege that the specific shampoo that she used contained benzene.”

“Rather,” the court wrote, “she asks the Court to infer that critical, foundational fact from Unilever’s later limited recall of specific product batches. While Unilever’s recall could, of course, reflect the possibility that earlier batches of the same …