Krause-Pettai v. Unilever United States, Inc.

CourtDistrict Court, S.D. California
DecidedSeptember 30, 2023
Docket3:20-cv-01672
StatusUnknown

This text of Krause-Pettai v. Unilever United States, Inc. (Krause-Pettai v. Unilever United States, Inc.) is published on Counsel Stack Legal Research, covering District Court, S.D. California primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Krause-Pettai v. Unilever United States, Inc., (S.D. Cal. 2023).

Opinion

1 UNITED STATES DISTRICT COURT 2 SOUTHERN DISTRICT OF CALIFORNIA 3 Nicole KRAUSE-PETTAI, et al., Case No.: 20-cv-1672-AGS-BLM individually and on behalf of 4 ORDER GRANTING DEFENDANT’S all others similarly situated, MOTIONS FOR SUMMARY 5 Plaintiffs, JUDGMENT (ECF 70) AND TO 6 v. EXCLUDE EXPERT TESTIMONY (ECF 71 & 72), AND DENYING 7 UNILEVER UNITED STATES, INC., PLAINTIFF’S CLASS- et al., 8 CERTIFICATION MOTION (ECF 57) Defendants. 9

10 This case is about useless empty space, known as “nonfunctional slack fill,” inside 11 underarm-deodorant sticks. Defendant argues, among other defenses, that federal law 12 preempts slack-fill suits regarding drugs and cosmetics, a matter of first impression in this 13 Circuit. 14 BACKGROUND 15 In this putative class action, four plaintiffs claim they were duped into buying 16 defendant Unilever’s deodorant and antiperspirant. They say the oversized containers 17 create the illusion of holding more than competitors’ same-weight items. (ECF 52, at 3, 18 10–12.) According to plaintiffs, much of Unilever’s products’ volume is nonfunctional 19 slack fill. (Id. at 11–12.) They seek class certification, alleging various unfair and deceptive 20 trade practices under state law. Unilever opposes certification and insists the case should 21 be thrown out on summary-judgment and federal-preemption grounds. 22 DISCUSSION 23 A. Preemption 24 As a threshold matter, Unilever contends that federal regulations preempt plaintiffs’ 25 state-law claims. “[S]tate laws that conflict with federal law are without effect.” Altria 26 Group, Inc. v. Good, 555 U.S. 70, 76 (2008) (cleaned up); see also U.S. Const., art. VI, 27 cl. 2 (Supremacy Clause). “Federal preemption can be either express or implied.” Chicanos 28 1 Por La Causa, Inc. v. Napolitano, 558 F.3d 856, 863 (9th Cir. 2009). Unilever relies only 2 on the express variety. 3 1. Express Preemption: The FDCA 4 To assure national uniformity, the Food, Drug, and Cosmetic Act expressly preempts 5 any state “requirement” for labeling or packaging cosmetics and nonprescription drugs— 6 including deodorants and antiperspirants—that is “different from or in addition to, or that 7 is otherwise not identical with,” federal rules. See 21 U.S.C. § 379r(a)(2) (nonprescription 8 drugs); id. § 379s(a) (cosmetics). The question is: Do the challenged state laws mandate 9 “requirements” that are (a) “identical with” federal standards or (b) “different from or in 10 addition to” them? 11 As relevant here, both the FDCA and California’s Sherman Food, Drug, and 12 Cosmetic Law set the same baseline requirements for drugs and cosmetics. They deem 13 such an item “misbranded” if “its labeling is false or misleading in any particular” or if its 14 “container” is “filled as to be misleading.” See 21 U.S.C. § 352(a)(1) (drugs; label); id. 15 § 352(i)(1) (drugs; container); id. § 362(a) (cosmetics; label); id. § 362(d) (cosmetics; 16 container); Cal. Health & Safety Code § 111330 (drugs; label); id. § 111390 (drugs; 17 container); id. § 111730 (cosmetics; label); id. § 111750 (cosmetics; container). Because 18 the Sherman Law’s standard “is identical to” the FDCA’s, it is not preempted. See Ebner 19 v. Fresh, Inc., 838 F.3d 958, 965 (9th Cir. 2016). 20 But California did not stop at that baseline. It added to it. The FDCA and Sherman 21 Law both generally forbid “misleading” labeling and packaging, but neither addresses 22 slack-fill limits on drugs or cosmetics. Yet the California Fair Packaging and Labeling Act 23 (CFPLA) goes one step farther, condemning any opaque container as “misleading” if “it 24 contains nonfunctional slack fill,” with some exceptions. See Cal. Bus. & Prof. Code 25 § 12606(b). The Ninth Circuit concluded that this exact regulatory scenario mandated 26 preemption in Del Real, LLC v. Harris, 636 F. App’x 956 (9th Cir. 2016). In the context 27 of “meat and poultry products,” it held that the CFPLA’s “nonfunctional slack fill 28 1 provisions” were “in addition to, or different than” the relevant federal statutes’ “general 2 prohibitions against containers ‘filled as to be misleading.’” Id. at 957. 3 Plaintiffs protest that slack-fill regulations may only be preempted by “an overt 4 decision,” not federal “silence” on the issue. (See ECF 77, at 15.) But Congress was not 5 silent here; it spoke clearly about what is preempted. In the FDCA, Congress meant to 6 preclude all state requirements that are “different from or in addition to,” or “otherwise not 7 identical with,” the federal regulatory regime for labeling and packaging drugs and 8 cosmetics. In National Meat Association v. Harris, 565 U.S. 452 (2012), the Supreme 9 Court held that a nearly identical preemption provision “sweeps widely” and blocks states 10 from imposing on the federal plan “any additional or different—even if non-conflicting— 11 requirements.” Id. at 459. Even assuming California’s slack-fill regulation doesn’t conflict 12 with the federal design, it “plainly adds to the regulatory burden faced by a manufacturer” 13 subject to the FDCA’s packaging and labeling constraints. See Del Real, LLC v. Harris, 14 966 F. Supp. 2d 1047, 1064 (E.D. Cal. 2013), aff’d, 636 F. App’x 956 (9th Cir. 2016). 15 Thus, the CPFLA’s slack-fill ban for drugs and cosmetics is preempted. 16 2. Preemptive Scope 17 The foregoing robs plaintiffs of a powerful arrow in their quiver: a per se rule that 18 nonfunctional slack fill is misleading. But it does not necessarily foreclose their claims 19 entirely, as Unilever urges. The FDCA “does not preempt state laws that allow consumers 20 to sue . . . manufacturers that label or package their products in violation of federal 21 standards.” See Ebner, 838 F.3d at 964 (discussing cosmetics). Plaintiffs argue that their 22 state-law claims enforce federal prohibitions on “misleading” packaging. But Unilever 23 insists that, according to the relevant federal agency, slack fill in drugs and cosmetics is 24 never misleading. 25 For support, Unilever points to two cases that held the Food and Drug 26 Administration’s failure to set explicit restrictions on slack fill in drugs and cosmetics is 27 “tantamount to a conscious decision by the agency to permit” it. See O’Connor v. Henkel 28 Corp., No. 14-CV-5547 (ARR)(MDG), 2015 WL 5922183, at *6 (E.D.N.Y. Sept. 22, 1 2015); Bimont v. Unilever U.S., Inc., No. 14-CV-7749 (JPO), 2015 WL 5256988, at *6 2 (S.D.N.Y. Sept. 9, 2015). Both opinions quote Astiana v. Hain Celestial Group, Inc., 3 783 F.3d 753 (9th Cir. 2015). But Astiana made the opposite point. The defense there 4 supposed that “the FDA’s failure to issue specific regulations” about the word “‘natural’ 5 on cosmetics labels” was “tantamount to a conscious decision by the agency to permit any 6 use of this term a manufacturer sees fit.” Id. at 758. The Ninth Circuit disagreed. It noted 7 that this “argument proves too much,” as it would allow a manufacturer to “make any 8 claim—wild, untruthful, or otherwise—about a product whose contents are not addressed 9 by a specific regulation.” Id. Even without precise federal guidelines, Astiana allowed 10 plaintiffs’ state-law suit alleging deceptive use of the word “natural” to proceed, as it 11 promoted the general federal prohibition on “false or misleading” labeling. Id. at 758–59.

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Krause-Pettai v. Unilever United States, Inc., Counsel Stack Legal Research, https://law.counselstack.com/opinion/krause-pettai-v-unilever-united-states-inc-casd-2023.