Kealani Distribution LLC v. Food and Drug Administration

CourtDistrict Court, E.D. Texas
DecidedFebruary 12, 2025
Docket4:22-cv-00856
StatusUnknown

This text of Kealani Distribution LLC v. Food and Drug Administration (Kealani Distribution LLC v. Food and Drug Administration) is published on Counsel Stack Legal Research, covering District Court, E.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Kealani Distribution LLC v. Food and Drug Administration, (E.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS SHERMAN DIVISION

KEALANI DISTRIBUTION LLC, ET § AL. § § v. § CIVIL NO. 4:22-CV-856-SDJ § FOOD AND DRUG § ADMINISTRATION, ET AL. §

MEMORANDUM OPINION AND ORDER When a federal agency promulgates a rule, the Regulatory Flexibility Act (“RFA”) requires the agency to either analyze how the rule will affect small businesses or certify that the rule will not have a “significant economic impact on a substantial number of small entities.” 5 U.S.C. §§ 603–604, 605(b). The requirements of the RFA are “purely procedural” and impose “no substantive constraint on agency decisionmaking.” Nat’l Tel. Coop. Ass’n v. FCC, 563 F.3d 536, 540 (D.C. Cir. 2009) (internal quotation marks and alteration omitted). An agency need only demonstrate a “reasonable, good-faith effort to carry out RFA’s mandate.” U.S. Cellular Corp. v. FCC, 254 F.3d 78, 88 (D.C. Cir. 2001) (citation and alteration omitted). Plaintiffs here include several small businesses that manufacture “e-liquids”— the nicotine-containing liquid in e-cigarettes—and a trade association (collectively, the “Manufacturers”).1 They challenge the FDA’s certification for a 2021 regulation

1 Plaintiffs include Kealani Distribution LLC, Diamond Vapor LLC, Johnny Copper LLC, SWT Global Supply, Inc., Carolina Vapor Mill LLC, Carolina Vapor Mill Woodruff Road, CVM3 LLC, and United States Vaping Association, Inc. (the “2021 Final Rule”)2 that clarifies the requirements for Premarket Tobacco Applications (“PMTA”). The FDA counters that its certification is proper. Before the Court are Plaintiffs’ Motion for Summary Judgment, (Dkt. #36), and

Defendants’ Cross Motion for Summary Judgment, (Dkt. #37). Having considered the parties’ briefing, the administrative record, and the applicable law, the Court concludes that the FDA made a reasonable, good-faith effort to comply with the RFA when promulgating the 2021 Final Rule. Accordingly, Plaintiffs’ Motion for Summary Judgment will be DENIED, and Defendants’ Cross Motion for Summary Judgment will be GRANTED.

I. BACKGROUND A. The FDA’s Authority to Regulate Tobacco The FDA first attempted to regulate tobacco three decades ago. In 1995, it proposed a rule to regulate the sale of cigarettes and smokeless tobacco to children.3 In support, the FDA cited several findings on the harmful effects of cigarette smoking and the addictiveness of nicotine.4 A year later, the FDA finalized the rule,5

2 Premarket Tobacco Product Applications and Recordkeeping Requirements, 86 Fed. Reg. 55300 (Oct. 5, 2021) (the “2021 Final Rule”). 3 Regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco Products to Protect Children and Adolescents, 60 Fed. Reg. 41314 (Aug. 11, 1995). 4 Some of these findings included that (1) tobacco use was the single leading cause of preventable death in the United States, id. at 41361; (2) more than 400,000 people died each year from tobacco-related illnesses, id.; and (3) “[c]igarettes kill more Americans each year than acquired immune deficiency syndrome (AIDS), alcohol, car accidents, murder, suicides, illegal drugs, and fires combined,” id. at 41314. 5 Regulations Restricting the Sale and Distribution of Cigarettes and Smokeless Tobacco to Protect Children and Adolescents, 61 Fed. Reg. 44396, 44397–99 (Aug. 28, 1996). concluding that it could regulate tobacco under the Federal Food, Drug, and Cosmetic Act (“FDCA”) because the “nicotine in cigarettes and smokeless tobacco is a ‘drug.’”6 Several tobacco companies successfully challenged the FDA’s conclusion in

federal court. In FDA v. Brown & Williamson Tobacco Corp., the Supreme Court held that “Congress ha[d] clearly precluded the FDA from asserting jurisdiction to regulate tobacco products.” 529 U.S. 120, 126, 120 S.Ct. 1291, 146 L.Ed.2d 121 (2000). For nearly a decade thereafter, the FDA did not assert—and Congress did not convey—the power to regulate tobacco products. But in 2009, Congress empowered the FDA to regulate the sale and marketing

of tobacco products by amending the FDCA through the Family Smoking Prevention and Tobacco Control Act (“TCA”). Pub. L. No. 111-31, 123 Stat. 1776 (2009) (codified at 21 U.S.C. § 387, et seq.). Congress recognized that prior efforts to regulate tobacco products “ha[d] failed adequately to curb tobacco use by adolescents,” id. § 2, 123 Stat. at 1777, and found that “[t]he use of tobacco products by the Nation’s children is a pediatric disease of considerable proportions that results in new generations of tobacco-dependent children and adults,” id. Based on these and related findings,

Congress determined that “comprehensive restrictions on the sale, promotion and distribution of [tobacco] products [we]re needed[.]” Id. To enforce such restrictions, the TCA vests the FDA with broad authority to address “the public health and societal problems caused by the use of tobacco products.” Id.

6 See id. at 44397. Along with provisions enabling the FDA to regulate tobacco products, the TCA imposes several requirements on tobacco-product manufacturers. Relevant here, the TCA prohibits manufacturers from marketing or selling any “new tobacco product”7

without first receiving FDA approval.8 21 U.S.C. § 387j(a)(2)(A)–(B). A “new tobacco product” is one that was “not commercially marketed in the United States as of February 15, 2007,” or any modified version of a tobacco product marketed after that date. Id. § 387j(a)(1)(A)–(B). To obtain FDA approval for a new tobacco product, a manufacturer must receive premarket authorization from the agency. The premarket-authorization

process begins when a manufacturer submits a PMTA. Id. § 387j(b). The PMTA must include “full reports of all information . . . concerning investigations which have been made to show the health risks of such tobacco product and whether such tobacco product presents less risk than other tobacco products.” Id. § 387j(b)(1)(A). PMTAs must also include “a full statement of the components, ingredients, additives, and properties” of the tobacco product; “the methods used in, and the facilities and controls used for, the manufacture” of the product; “specimens of the labeling

proposed to be used” for the product; and “such other information . . . as the Secretary may require.” Id. § 387j(b)(1)(B)–(C), (F)–(G).

7 Under the TCA, “tobacco products” include “all cigarettes, cigarette tobacco, roll- your-own tobacco, and smokeless tobacco and . . . any other tobacco products that the Secretary [of Health and Human Services] by Regulation deems to be subject to this chapter.” 21 U.S.C. § 387a(b). 8 While the TCA has a grandfather provision, the parties agree that the e-liquid products at issue here do not fall under it. The FDA examines PMTAs for information about the product’s “risks and benefits to the population as a whole,” evaluating the “likelihood that existing users of tobacco products will” quit or significantly reduce their use of more harmful tobacco

products and the “likelihood that those who do not use tobacco products will start.” Id. § 387j(c)(4).

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Kealani Distribution LLC v. Food and Drug Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/kealani-distribution-llc-v-food-and-drug-administration-txed-2025.