The Non-Financial Ledger: What This Actually Cost Real People

Regina Brookshier walked into a ULTA store in Rancho Cucamonga on a June afternoon in 2024. She wasn’t looking to make a political statement. She was buying shampoo. She read the label the way most people do — looking for reassurance that she wasn’t putting something harmful on her body, that the product was what it said it was. On the back of the bottle, in clear, contrasting font, the words said “Made in the USA.” She trusted that.

She paid $34.99. That’s real money. For a lot of people, that’s two or three hours of work after taxes. The purchase wasn’t casual — she chose that product, specifically, because she believed the claim. She believed she was putting her money toward American workers. She believed she was getting ingredients held to American agricultural and safety standards. She believed the bottle in her hand was what the company told her it was.

It wasn’t. The Tea Tree Special Shampoo she purchased contains tea tree oil — the product’s entire identity, the reason it’s called Tea Tree, the thing printed in the product name — that comes from Australia. It always has. Tea tree is endemic to the Australian continent. It has never been commercially harvested in the United States. The jojoba in that same bottle? The Food and Agriculture Organization of the United Nations documents that jojoba is not produced in commercial quantities in the US. None of that was on the label. What was on the label was a flat, unqualified promise that the product was “Made in the USA.”

Sam Lauer got fooled the same way, repeatedly. He’s a regular Paul Mitchell customer based in Cook County, Illinois. He bought the Tea Tree Lavender Mint Moisturizing Shampoo, the Tea Tree Lemon Sage Thickening Shampoo, the conditioners, the grooming pomade — multiple orders, over several months, from August 2024 through February 2025. Each time, the product description on FragranceNet.com restated the “Made in USA” claim. Each time, he believed it. He bought in bulk. He paid $59.99 for a large shampoo. He paid $56.99 for another. He wasn’t browsing — he was stocking up on something he thought was trustworthy.

Here’s the thing that doesn’t show up in a damages calculation: these weren’t people trying to game the system. They were people trying to make good choices with their money. Many consumers, when they seek out American-made products, do so because they believe it means better labor standards, stricter environmental oversight, and higher quality control. They’re trying to opt out of supply chains where workers get exploited and corners get cut. JPMS sold them a story that let them feel like they were doing the right thing — and pocketed the premium that story commands — while quietly sourcing ingredients from wherever it was cheapest or most convenient.

The lawsuit notes that Plaintiffs “believed, at the time of purchase, that the Products were of superior quality and that they were supporting U.S. jobs, the U.S. economy, the environment, and ethical working conditions by purchasing a product made with U.S.-sourced ingredients.” That belief was manufactured. It was manufactured by a company with over $1 billion in annual revenue that was fully aware of the federal rules around “Made in USA” labeling and chose to ignore them anyway.

Brookshier filed a formal legal demand with JPMS in October 2024, giving the company a 30-day window to fix its labels and make restitution. California law provides for that. JPMS received the notice. JPMS did not cure the violations. The labels did not change. Brookshier had to file suit.

The complaint states plainly: “Plaintiffs want to purchase the Class Products again, but they cannot be certain that they would not be misled again in the future unless and until Defendant makes appropriate changes.” That sentence carries weight. These aren’t people who hate Paul Mitchell products. They’re people who liked them enough to keep buying them — and now cannot trust the company enough to do so. That erosion of trust is a real harm, and it isn’t captured in any refund calculation.

Legal Receipts: What the Complaint Says, Verbatim

The complaint filed by Kazerouni Law Group, APC on March 7, 2025 does not mince words. The following are direct quotes from court documents, each followed by a breakdown of what they establish.

“Defendant advertised, marketed, promoted, and sold the Class Products as ‘Made in the USA,’ without disclosing the use of foreign ingredients and/or components, when in fact, this claim was false.” Class Action Complaint, ¶27 — Case No. 1:25-cv-02438

• This establishes the core fraud: the misrepresentation was not accidental omission but active advertising of a false origin claim across all sales channels simultaneously.
• The phrase “when in fact, this claim was false” removes any ambiguity about whether this could be a technicality. The complaint states the claim was false, full stop.
• By including marketing, advertising, promotion, and sales all in one sentence, the complaint signals that every touchpoint in JPMS’s commercial operation carried the lie.

“The Products purchased by Plaintiffs all contain tea tree oil—the namesake and key ingredient of Defendant’s Tea Tree product line—which is not sourced from the United States. Nevertheless, each and every container of Defendant’s tea tree products claims to be ‘Made in the USA’ without any qualification.” Class Action Complaint, ¶52 — Case No. 1:25-cv-02438

• Tea tree is the defining ingredient of JPMS’s most prominent product line, not a trace additive. Sourcing it from Australia while claiming US origin is a structural deception built into the product’s identity, not a peripheral one.
• The complaint cites Wikipedia’s entry for Melaleuca alternifolia to establish that tea tree is “endemic to Australia” — the scientific record directly contradicts the label.
• “Each and every container” leaves no room for JPMS to argue that only some products were mislabeled. The violation is universal across the Tea Tree line.

“Given its expansive resources and operational sophistication, it is difficult to understand why Defendant so clearly violated the well-established laws, rules, and regulations surrounding the use of ‘Made in the USA’ or any derivative thereof, other than to deceive consumers and for its own personal financial gain.” Class Action Complaint, ¶25 — Case No. 1:25-cv-02438

• This is the complaint directly calling out willful conduct. A $1 billion company has legal teams, compliance departments, and supply chain managers. Ignorance of the FTC’s Made in USA rules is not a credible defense.
• The complaint frames this as a deliberate business decision made for financial gain, laying the groundwork for punitive damages claims — which require proof of intentional or reckless misconduct.

“Defendant’s MVRCK by MITCH Beard Oil prominently states ‘Made in the USA’, without qualification, on the back panel, yet it contains shea butter that is not sourced from the United States.” Class Action Complaint, ¶56 — Case No. 1:25-cv-02438

• The shea tree grows exclusively in Africa. The complaint cites the Wikipedia distribution map for Vitellaria (the shea species) to confirm this. There is no American shea supply chain.
• This violation extends beyond the Tea Tree line to JPMS’s men’s grooming products, confirming the “Made in USA” fraud is company-wide policy, not line-specific.

“Pursuant to California Civil Code § 1782(a), on or about October 17, 2024, Plaintiff Brookshier sent Defendant a notice and demand for corrective action (the ‘CLRA Demand’) via certified mail, informing Defendant of its violations of the CLRA and demanding that they cease and desist from such violations, as well as make full restitution by refunding all monies received in connection therewith. As the alleged violations were not cured by Defendant within 30 days of the CLRA Demand and remain unaddressed, Plaintiff Brookshier on behalf of herself and the Class, seeks damages and attorneys’ fees.” Class Action Complaint, ¶¶154-155 — Case No. 1:25-cv-02438

• California law gives companies a 30-day window to fix verified consumer protection violations before being sued. JPMS received a certified letter in October 2024 and did nothing. That is the legal equivalent of being caught, being warned, and shrugging.
• This non-response now enables Brookshier and the California class to seek both damages and attorneys’ fees, making the case significantly more financially consequential for JPMS than if it had simply updated its labels.
• The failure to cure also supports the complaint’s argument that JPMS’s conduct is intentional and ongoing, not an administrative oversight it would have corrected if given the chance.

Societal Impact Mapping: Who Gets Hurt and How

Public Health

When a company claims “Made in the USA,” consumers reasonably assume they’re getting ingredients regulated by US agencies. That assumption collapses entirely when the key ingredients come from foreign supply chains with different oversight regimes.

• US-sourced ingredients for topical products are subject to strict EPA, FDA, and USDA regulatory frameworks covering pesticide residue limits, contamination testing, and ingredient safety standards. Foreign-sourced ingredients are not subject to those same requirements, creating an unequal and undisclosed risk profile for products applied directly to skin and scalp.
• The complaint specifically flags this concern: “Foreign-sourced, grown, or manufactured ingredients and components are not subject to the same U.S. standards and may pose greater risks to consumers.” Consumers cannot make informed risk assessments about a product they’re told is domestically produced when it is not.
• Hair care products are applied to the scalp — a highly vascular area of the body — and left to absorb. The standard for ingredient safety and sourcing documentation is not trivial for this product category. By hiding foreign sourcing, JPMS removes consumers’ ability to investigate or avoid ingredients they might have concerns about.
• The class covers “hundreds of thousands of units” of products sold across Illinois and California alone. The potential scale of consumer exposure to undisclosed foreign-sourced ingredients in topical products is not a minor footnote.

Economic Inequality

The “Made in USA” premium is a real pricing phenomenon. Companies that earn that designation command higher prices. JPMS collected that premium while delivering a foreign-sourced product — a transfer of wealth from working consumers to a billion-dollar company built on a false claim.

• Plaintiff Lauer paid $59.99 for a large bottle of shampoo and $56.99 for another in a single November 2024 purchase. That’s over $116 for two bottles of shampoo from a brand whose premium pricing was justified, in significant part, by a US origin claim that was false.
• The complaint alleges JPMS “either charged a premium for the Class Products compared to its competitors or gained a competitive advantage by having the Class Products chosen over others based on false, unqualified ‘Made in the USA’ claims.” Both mechanisms are economically predatory: extract extra money or extract extra market share. Either way, honest competitors lose ground to a company that cheats.
• Competitors — including OGX, Giovanni, and Redken — properly qualify their “Made in USA” claims with language like “with globally sourced ingredients.” The complaint includes images of these competitor labels as evidence. This creates a structurally unfair market: companies that follow the law lose customers to a company that doesn’t.
• The proposed class encompasses every person in Illinois and California who bought any JPMS product labeled “Made in USA” in the last four years. Given JPMS’s distribution through Target, Walgreens, CVS, ULTA, Amazon, and professional salons, the number of affected consumers runs into the thousands at minimum, with aggregate damages estimated to exceed $5,000,000.
• Low-income consumers who buy in bulk to save money — as Lauer did, purchasing 33.8-oz bottles — are disproportionately harmed when premiums are applied to everyday personal care items. A $5 to $10 premium on shampoo is meaningless to a billionaire corporation. It is not meaningless to a working person buying a product they’ll use every week.
• The unjust enrichment claim establishes that JPMS was enriched specifically at the expense of its customers — not through legitimate value creation, but through deception. The complaint asks for disgorgement of all ill-gotten profits, meaning the court could force JPMS to surrender the financial gains built on the false label.

The Cost of a Life Metric: What the Numbers Say

What Now? How to Fight Back

The class action is active and seeking members. If you bought any John Paul Mitchell Systems product labeled “Made in the USA” in Illinois or California within the last four years, you may be a class member. Here is what you need to know and what you can do right now.

The Corporate Targets

The defendant is the corporation. Named roles and individuals from the source document are not disclosed beyond the corporate entity, so the accountability sits with:

• John Paul Mitchell Systems, a California corporation headquartered at 20705 Centre Pointe Parkway, Santa Clarita, California 91350. This is the company that manufactured, labeled, distributed, and sold the products under false origin claims.
• The officers, directors, and employees of JPMS who approved label language, supply chain decisions, and marketing materials carrying the false “Made in USA” claim — all of whom are excluded from the class and remain in JPMS’s liability orbit.

Watchlist: Regulatory Bodies With Jurisdiction

• Federal Trade Commission (FTC): The FTC’s Made in USA Labeling Rule (16 C.F.R. § 323, effective 2021) is the direct federal law JPMS allegedly violated. File a complaint at ftc.gov/complaint. The FTC has authority to impose civil penalties for MUSA Rule violations.
• California Attorney General: California’s False Advertising Law (Bus. & Prof. Code § 17500) and Unfair Competition Law (Bus. & Prof. Code § 17200) both cover the conduct alleged in this case. The AG’s office can pursue enforcement independent of the class action.
• Illinois Attorney General: The Illinois Consumer Fraud and Deceptive Business Practices Act (815 ILCS 505/1) is one of the statutes named in the complaint. The AG can investigate and act on consumer protection violations in the state.
• Consumer Product Safety Commission (CPSC): While primary jurisdiction here is FTC and state consumer protection law, the CPSC has overlapping interest in ingredient disclosure and product safety for topical consumer products.
• State Attorneys General (all states): JPMS sells nationwide through Target, Walgreens, CVS, Amazon, and salons. If you are outside Illinois or California, your state’s AG may have parallel consumer protection jurisdiction.

How to Take Action

• Check if you qualify for the class. If you purchased any JPMS product labeled “Made in the USA” in Illinois or California between approximately March 2021 and March 2025, contact the attorneys of record: Kazerouni Law Group, APC, 245 Fischer Avenue Ste. D1, Costa Mesa, California 92626. Attorney Abbas Kazerounian (ak@kazlg.com) is lead counsel. Cases filed at ClassAction.org are searchable.
• File an FTC complaint about the specific product you purchased. Go to ftc.gov/complaint and select “Shopping and Buying” then “Made in USA claims.” The more individual complaints the FTC receives, the stronger the case for enforcement action beyond this single lawsuit.
• Leave reviews that tell the truth. On Amazon, Target, ULTA, and Walgreens product pages for Paul Mitchell items, consumer reviews noting the presence of foreign-sourced ingredients and linking to the court filing are legitimate and protected speech. This is how future buyers get warned.
• Switch to transparently labeled brands. OGX, Giovanni, and Redken are named in the complaint as brands that already use qualified “Made in USA with globally sourced ingredients” language. Voting with your dollars is a market signal that honesty is worth more than a flag on a label.
• Share this story with labor and consumer advocacy networks. Mutual aid organizations, local consumer protection groups, and worker advocacy networks should know that Paul Mitchell’s $1 billion business model includes charging a patriotism premium that the product does not legally support.
• Organize locally. If you work in or frequent professional hair salons — one of JPMS’s main distribution channels — talk to stylists about this case. Salon professionals recommend these products to clients. They deserve to know what they are recommending, and clients deserve informed consent about what is going on their scalp.