In 2007, Stacy Holk purchased two Snapple drinks labeled as “all natural.” According to a class action she later brought in New Jersey state court against Snapple for deceptive labeling, Holk claimed that the drinks contained high-fructose corn syrup and other artificial ingredients. Snapple removed the case to federal court, and the trial court later dismissed the case, noting that while Congress did not explicitly preempt state labeling laws with the Federal Food, Drug and Cosmetic Act (“FDCA”) and the Nutrition Labeling and Education Act (“NLEA”), it “impliedly preempted” them and other state labeling laws “would create obstacles to the accomplishment Congress’s objectives.”
On appeal, the Third Circuit Court of Appeals disagreed, holding that the FDCA did not create “exhaustive” regulations of juice products. The court further noted that, even though the FDA had deemed high-fructose corn syrup as “natural,” the policy statement did not preempt plaintiff’s claims. Accordingly, the court reversed the dismissal and reinstated the class action suit.
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