Pom Wonderful, LLC v. The Coca-Cola Company (2013)
- Docket
- 12-761
- Decided
- 2013-01-01
Summary
Question: Did the U.S. Court of Appeals err when it held that FDA regulations barred Pom Wonderful's claim for false advertising under the Lanham Act? Conclusion: Yes. Justice Anthony M. Kennedy delivered the opinion for the 8-0 majority. The Court held that, while it is the duty of the courts to harmonize statutes, the best way to do that in this case does not entail barring POM Wonderful's Lanham Act claims. Neither the Lanham Act nor the FDCA explicitly forbids or limits Lanham Act claims on labels that the FDCA regulates. The Court held that, because the Lanham Act and the FDCA have coexisted since the passage of the Lanham Act in 1946 without Congress addressing the issue, Congress has evidently not seen a problem with their potential interferences. Therefore, holding that the FDCA precludes the operation of the Lanham Act would represent a disregard for the legislative intent of having the two statutes complement one another. Justice Stephen G. Breyer did not take part in the discussion or decision of this case.