POM Wonderful LLC v. Coca-Cola Co.

When a federal statute, such as the Lanham Act, is complementary with a federal statute, such as the Food, Drug, and Cosmetic Act, and neither explicitly provide otherwise, there is no preclusion.

Petitioner filed a Lanham Act suit against Respondent alleging that one of Respondent’s juice container labels misleads consumers into believing the product inside consisted predominantly of more expensive juices, when in fact it consisted predominantly of less expensive juices. Petitioner alleged that the ensuing confusion caused them to lose sales.

The District Court granted partial summary judgment to Respondent, holding that the Federal Food, Drug and Cosmetic Act (FDCA) and its regulations preclude Lanham Act challenges to the name and label of Respondent’s juice blend. The Ninth Circuit affirmed in relevant part.

Since this is really a preclusion case, the statutes are complementary, and because neither the Lanham Act nor the FDCA expressly forbids Lanham Act claims challenging labels that are regulated by the FDCA, the Supreme Court reversed, holding that competitors may bring Lanham Act claims like Petitioner’s, challenging food and beverage labels regulated by the FDCA.