News & Analysis as of

Product Labels Preemption

McGuireWoods LLP

State Court Rejection of Federal Preemption in Product Liability Claim Highlights Uncertainty for Manufacturers

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On Feb. 11, 2025, the Missouri Court of Appeals for the Eastern District in Durnell v. Monsanto Co., upheld a jury verdict awarding $1.25 million in compensatory damages to plaintiff John Durnell from defendant Monsanto Co....more

Mayer Brown

Regulatory and Legal Implications of the Surgeon General’s Call For Cancer Warning On Alcohol Labels

Mayer Brown on

On January 3, 2025, outgoing US Surgeon General Dr. Vivek Murthy released a new advisory outlining the alleged causal link between alcohol consumption and cancer, claiming “numerous high-quality observational studies and...more

Segal McCambridge

The Evolving Landscape of Federal Preemption in Failure to Warn Claims

Segal McCambridge on

For over three decades, federal preemption of state failure to warn claims has served as a powerful defense in strict liability tort cases. Courts have consistently dismissed lawsuits challenging the adequacy of warnings for...more

Fishman Haygood LLP

U.S. Third Circuit Rejects Claims of Preemption and Allows Fosamax Cases to Proceed

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In 2022, over 500 plaintiffs filed a case alleging that Merck Sharp & Dohme Corp., a drug manufacturing company, failed to provide adequate warnings that one of their drugs increased the risk of atypical femoral fractures....more

Goodell, DeVries, Leech & Dann, LLP

California Court of Appeal Affirms that Federal Impossibility Preemption Defeats Prop 65 Warning Claims for Over-the-Counter...

The manufacturers and retailers of over-the-counter generic Zantac (ranitidine) have secured an important appellate victory in California state court. On March 9, the San Francisco-based California Court of Appeal, First...more

Perkins Coie

Tenth Circuit Holds “Made in USA” Challenge Is Preempted

Perkins Coie on

Last week, a split-panel of the Tenth Circuit affirmed the district court’s dismissal of a false advertising case in which plaintiffs alleged that “Product of the U.S.A.” labels on various beef products were misleading...more

King & Spalding

Spotlight on PFAS and Other Substances in Cosmetics Likely to Grow in 2022

King & Spalding on

This year – 2022 – may finally be the year that the effort to modernize safety standards in the U.S. for cosmetics and other personal care products, which has been ongoing since 2013, comes to fruition. If so, the new...more

Bilzin Sumberg

Cohen v. ConAgra- Poultry False Advertising Claims Survive Despite Federally Preempted Product Mislabeling Claim

Bilzin Sumberg on

In October of this year, the Ninth Circuit Court of Appeals analyzed the issue of federal preemption in the context of poultry product labeling. The plaintiff in Cohen v. ConAgra Brands, Inc., brought a putative class action...more

Patterson Belknap Webb & Tyler LLP

Fowl Ground: Ninth Circuit Reaches Unusual Result Applying Federal Preemption Law in Poultry Labeling Case

A few months ago, we analyzed the Ninth Circuit’s decision in Webb v. Trader Joe’s Company, No. 19-56389 (June 4, 2021), which held that a private plaintiff’s challenge to poultry labeling claims were preempted by federal...more

Kilpatrick

Ninth Circuit holds product label preemption defense requires evidence and does not extend to materially-different statements on...

Kilpatrick on

Takeaway: The quickest, most efficient way to kill a putative class action remains a successful Rule 12 motion to dismiss. But in ruling on such a motion, a district court generally cannot stray beyond the allegations in...more

Morrison & Foerster LLP - Left Coast Appeals

This Week at the Ninth: Cars and Chickens

This week, the Ninth Circuit explores the constitutionality of a state statute aimed at protecting consumer information given to car dealers, and clarifies the preemptive scope of federal regulatory approval of food labels. ...more

Proskauer - Advertising Law

The Legal “Pecking Order”: Ninth Circuit Finds Poultry Labeling Claims Preempted

In a unanimous precedential decision, a Ninth Circuit panel recently affirmed the dismissal of a putative class action against Trader Joe’s, which alleged that the statement “Up to 5% Retained Water” on Trader Joe’s poultry...more

Patterson Belknap Webb & Tyler LLP

Ninth Circuit Cries “Fowl” on Challenge to Poultry Labels

Earlier this month, this blog analyzed the preemption provisions of the Federal Meat Inspection Act (FMIA) and the Poultry Products Inspection Act (PPIA), which together regulate the labeling of meat and poultry products.  We...more

Patterson Belknap Webb & Tyler LLP

Seventh Circuit Weighs In On Reasonable Consumer Standard in 100% Grated Cheese Case

This blog previously reported on the Seventh Circuit oral argument in Bell v. Albertson Companies Inc.—a case turning on whether a reasonable consumer would understand the phrase “100% Grated Parmesan cheese” on a cheese...more

Patterson Belknap Webb & Tyler LLP

In Hair Supplement Case, Ninth Circuit Rejects Bald Attempt to Escape Preemption

Federal law expressly authorizes manufacturers of dietary supplements to make “structure/function” claims—that is, claims about the effect of particular nutrients on the structure or function of the human body.  (Think:...more

Patterson Belknap Webb & Tyler LLP

Federal Court Wipes Away Challenge to Nivea Lotion on Preemption Grounds

What distinguishes a “cosmetic” from a “drug” under the Federal Food, Drug, and Cosmetic Act (FDCA)? The FDA has struggled to offer clear guidance on the distinction, but the classification as one or the other (or both)...more

Faegre Drinker Biddle & Reath LLP

Circuit Does Not Quite Clarify the Supreme Court’s Not-Quite-Clarification of “Clear Evidence” in Albrecht

The U.S. Supreme Court’s 2019 decision in Merck Sharp & Dohme, Inc. v. Albrecht, 139 S.Ct. 1668 (2019), discussed... addressed impossibility preemption in label change lawsuits. In Albrecht, the Supreme Court purported to...more

Faegre Drinker Biddle & Reath LLP

Biotin Supplement Suit Dismissed on Preemption Grounds

A California federal judge tossed a proposed class action against allegedly “worthless” biotin dietary supplements on preemption grounds earlier this week, citing the Ninth Circuit’s recent decision in Dachauer v. NBTY, Inc.,...more

Butler Snow LLP

Pro Te: Solutio – Vol. 12, No. 2

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Pro Te: Solutio returns for its second edition of 2019. As the year grinds on, our attorneys at Butler Snow are taking proactive and creative steps to confront and solve the issues that affect our areas of practice. The...more

Shook, Hardy & Bacon L.L.P.

Dietary Supplement & Cosmetics Legal Bulletin l June 2019

LEGISLATION, REGULATIONS & STANDARDS - FDA Study Finds Sunscreen is Absorbed into Bloodstream - JAMA has published a study conducted by researchers at the U.S. Food and Drug Administration (FDA) Center for Drug...more

Butler Snow LLP

Express Preemption of Consumer Protection Actions: Preventing a Patchwork of State Drug and Device Regulations

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The Supremacy Clause of the United States Constitution declares federal law to be the “supreme Law of the Land.” Thus, when federal law and state law conflict, the state law is “preempted,” or rendered without effect. Under...more

Carlton Fields

Food for Thought: Under California Law, Individual Class Members Need Not Show Reliance on Allegedly Misleading Statements at Time...

Carlton Fields on

In its latest opinion addressing class action claims related to allegedly misleading labels, the Ninth Circuit Court of Appeal held that individual class members need not show they relied on allegedly misleading statements...more

Shook, Hardy & Bacon L.L.P.

Food & Beverage Litigation Update | October 2017 #2

Chicago Repeals SSB Tax After Two Months of Enforcement - Chicago officials have voted to repeal a sugar-sweetened beverage (SSB) tax approved in November 2016 by the Cook County Board of Commissioners but delayed by a...more

Shook, Hardy & Bacon L.L.P.

Food & Beverage Litigation Update | September 2017 #3

FDA Announces Final FSMA Produce Safety Rule - The U.S. Food and Drug Administration (FDA) has announced that the produce safety rule of the Food Safety and Modernization Act of 2010 (FSMA) is now final, establishing...more

Butler Snow LLP

Pro Te: Solutio Vol. 8 No. 2

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Summer is in full swing and certain topics are (staying) hot—especially regulatory issues, from new proposed rules to challenges to case law to strategic considerations. Generic preemption remains a hot topic. In Storm...more

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