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ALTRIA v. GOOD - BRIEF FOR RESPONDENTS (PDF) 

Jump to full article: ABA Journal (American Bar Association), 2008-06-11

Intro:

QUESTIONS PRESENTED

1. Whether the Federal Cigarette Labeling and Advertising Act expressly preempts state-law claims that a cigarette company violated Maine’s generally applicable prohibition on deceptive practices by falsely representing its cigarettes using the descriptors “light” and/or “lowered tar and nicotine.”

2. Whether respondents’ state-law claims based on the fraudulent use of such descriptors are impliedly preempted notwithstanding that the Federal Trade Commission has never authorized, encouraged, or required the use of such descriptors. . . .

The D.C. Circuit’s decision in Brown & Williamson confirms that the FTC could not have required the companies to use the Cambridge Method. At issue was a district court injunction requiring that Brown & Williamson, in its marketing of light cigarettes, “justify the advertisement of results from a different system of testing which it considers superior to the FTC system.” 778 F.2d at 44. The court invalidated that provision of the injunction, reasoning that, “[b]ecause the FTC has not adopted its system of testing pursuant to a Trade Regulation Rule under section 18 of the FTC Act, one cannot say that the FTC system constitutes the only acceptable one available for measuring milligrams of tar per cigarette.”

Respondents’ position and the decision below accord with positions taken by the Solicitor General in Watson: “[t]he FTC has not required [Philip Morris] to use the Cambridge Method to determine tar and nicotine levels or to report the results of those tests in its advertising.” U.S. Watson Cert. Br. 9. The Solicitor General also rejected Philip Morris’s reliance on the 1970 voluntary agreement, stating that it is improper to “treat[] the [cigarette] companies’ agreement as if it were the equivalent of an FTC regulation.” Id.21

More fundamentally, even if the FTC could be understood to have required such disclosures or use of the Cambridge Method, that would have no bearing on this case. Respondents allege that Philip Morris made “[f]alse[]” claims that certain of its cigarettes are “‘light’ and/or deliver[] lowered tar and nicotine.” JA32a; see JA31a. Respondents challenge descriptors, not the Cambridge Method or factual statements of tar and nicotine yields based on that method. Thus, Philip Morris’s implied preemption theory misses the central claim of respondents’ case.

* * *

In Cipollone, this Court held that Congress did not intend to preempt state-law actions for frauds committed by cigarette companies in the marketing of cigarettes. In asking this Court to overrule Cipollone, Philip Morris asks for immunity from longstanding state deceptive-practices statutes. Given the well-documented deceptions by cigarette companies over many decades to lull consumers into smoking so-called “light” cigarettes notwithstanding the health risks, and given the absence of legally binding FTC actions that would displace state-law damages actions, respondents’ claims to recompense consumers for the economic consequences of Philip Morris’s fraud should be permitted to proceed.

CONCLUSION

The judgment of the court of appeals should be affirmed.

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