Altria Group, Inc. v. Good, 555 U.S. 70 (2008)
Primary Holding
The Federal Cigarette Labeling and Advertising Act does not expressly or impliedly pre-empt state-law claims regarding fraudulent advertising practices, allowing consumers to pursue claims under state unfair trade practices laws.
In the case of Altria Group, Inc. v. Good, consumers who smoked "light" cigarettes claimed that the company misled them by advertising these cigarettes as being less harmful than regular ones, even though they knew this wasn't true. The Supreme Court ruled that consumers can still pursue claims against companies for deceptive advertising, even if federal laws regulate cigarette labeling. This ruling is important because it gives consumers the right to hold companies accountable for misleading marketing practices, especially if they feel they were tricked into buying a product based on false claims. If you believe a company has misled you about a product's safety or effectiveness, this case supports your right to take action.
AI-generated plain-language summary to help you understand this case
In Altria Group, Inc. v. Good, the underlying dispute arose from claims made by respondents, Stephanie Good and others, who had been long-time smokers of "light" cigarettes manufactured by petitioners, Philip Morris USA, Inc. and Altria Group, Inc. The respondents alleged that the petitioners violated the Maine Unfair Trade Practices Act (MUTPA) by fraudulently marketing their "light" cigarettes as delivering less tar and nicotine than regular cigarettes, despite the petitioners' knowledge that this claim was misleading. The respondents contended that the marketing of "light" cigarettes misrepresented their health risks, as smokers often engaged in compensatory behaviors that negated the purported benefits of lower tar and nicotine levels. The procedural history began when the respondents filed a complaint in federal court, invoking diversity jurisdiction. They sought to hold the petitioners accountable for their alleged deceptive marketing practices under the MUTPA. The petitioners responded by moving for summary judgment, arguing that the Federal Cigarette Labeling and Advertising Act (Labeling Act) pre-empted the respondents' state-law claims. The District Court initially ruled in favor of the petitioners, granting summary judgment based on this pre-emption argument. However, the Court of Appeals reversed this decision, leading to the petitioners seeking review from the Supreme Court, which ultimately affirmed the appellate court's ruling. The case is situated within a broader context of tobacco regulation and consumer protection, particularly regarding the marketing of cigarettes. The respondents' claims were grounded in the assertion that the tobacco industry had long engaged in misleading advertising practices, particularly with "light" cigarettes, which were marketed as a healthier alternative. This case highlights the tension between state consumer protection laws and federal regulations governing tobacco advertising, as well as the ongoing public health concerns related to smoking and tobacco use.
Whether the Federal Cigarette Labeling and Advertising Act preempts state law claims under the Maine Unfair Trade Practices Act regarding the marketing of "light" cigarettes.
The judgment is reversed.
- Court
- Supreme Court
- Decision Date
- October 6, 2008
- Jurisdiction
- federal
- Case Type
- landmark
- Majority Author
- Stevens
- Damages Awarded
- N/A
- Data Quality
- high
Watson v. Philip Morris Cos., 551 U.S. 142 (2007)
Consumer WonThe federal officer removal statute does not permit a defendant to remove a state-court action to federal court simply because a federal regulatory agency directs, supervises, and monitors the company’s activities in detail; the company must be acting under the direct authority of a federal officer in relation to the specific conduct being challenged.
Rowe v. New Hampshire Motor Transp. Assn., 552 U.S. 364 (2008)
Consumer LostThe federal law pre-empts state laws that regulate the delivery of tobacco products when those regulations are related to the price, route, or service of motor carriers, as established by the Federal Aviation Administration Authorization Act of 1994.
Warner-Lambert Co. v. Kent, 552 U.S. 440 (2008)
Consumer LostThe Supreme Court affirmed the judgment of the lower court by an equally divided Court, indicating that the decision of the lower court stands without establishing a new legal principle or rule.
Philip Morris USA v. Williams, 549 U.S. 346 (2007)
Consumer LostA jury may not base a punitive damages award on its desire to punish a defendant for harm caused to individuals not before the court, as doing so would violate the Due Process Clause by constituting a taking of property without due process.