## Facts

- POM Wonderful LLC sold pomegranate-based juice products, including a pomegranate–blueberry blend.
- The Coca-Cola Company (Minute Maid) sold a product labeled “Pomegranate Blueberry,” described as a “flavored blend of 5 juices,” with prominent fruit imagery.
- The product allegedly contained about 99.4% apple and grape juice and trace amounts of pomegranate and blueberry juices.
- POM alleged the label and marketing misled consumers about the product’s contents and diverted sales from POM.
- POM sued under § 43(a) of the Lanham Act for false or misleading advertising and asserted related California state-law claims.
- Coca-Cola argued the label complied with the FDCA and FDA regulations and that this federal labeling regime barred a Lanham Act challenge.
- The district court granted partial summary judgment for Coca-Cola, concluding the FDCA and FDA regulations barred Lanham Act challenges to the product name and label and preempted the state-law claims; the Ninth Circuit affirmed.
- The Supreme Court granted certiorari and reviewed whether the FDCA regime foreclosed the competitor suit under the Lanham Act.

## Issues

1. Whether the FDCA and FDA juice-labeling regulations preclude a competitor’s Lanham Act § 43(a) false-advertising claim challenging a food or beverage label regulated by the FDCA.

## Decision

- The Supreme Court unanimously reversed the Ninth Circuit and remanded.
- The Court held the FDCA does not preclude Lanham Act claims challenging food and beverage labels regulated by the FDCA.
- The Court rejected the argument that FDCA compliance or FDA regulatory coverage insulates labeling from Lanham Act scrutiny.

## Legal Principles

- Federal statutory “preclusion” (one federal statute displacing a cause of action under another) requires clear support in statutory text or established interpretive principles; it is not presumed.
- Neither the FDCA nor the Lanham Act expressly bars Lanham Act suits challenging labels regulated by the FDCA.
- Implied repeal of a federal statute by another is strongly disfavored and requires a clear conflict; the FDCA and Lanham Act can operate concurrently.
- The FDCA’s public-health labeling regime and the Lanham Act’s competitor-enforced false-advertising remedy address different harms and may function side by side.
- The FDCA’s lack of a private right of action does not, by itself, foreclose competitor suits under the Lanham Act.
- Congress’s choice to expressly preempt certain state misbranding rules, without restricting Lanham Act actions, supports coexistence rather than displacement of Lanham Act remedies.

## Conclusion

The Court held that the FDCA and FDA labeling regulations do not bar competitors from bringing Lanham Act false-advertising claims challenging allegedly misleading food and beverage labels, and it sent the case back for further proceedings under the Lanham Act standard.


POM Wonderful LLC v. Coca-Cola Co., 134 S. Ct. 2228 (2014)