R.J. Reynolds Tobacco Company v. United States Food And Drug Administration

CourtDistrict Court, E.D. Texas
DecidedJanuary 13, 2025
Docket6:20-cv-00176
StatusUnknown

This text of R.J. Reynolds Tobacco Company v. United States Food And Drug Administration (R.J. Reynolds Tobacco Company v. United States 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
R.J. Reynolds Tobacco Company v. United States Food And Drug Administration, (E.D. Tex. 2025).

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF TEXAS No. 6:20-cv-00176 R.J. Reynolds Tobacco Co. et al., Plaintiffs, v. U.S. Food & Drug Administration et al., Defendants.

OPINION AND ORDER Plaintiffs challenge an FDA rule that requires cigarette pack- aging and advertising to bear health warnings that have both graphical and textual components. Tobacco Products; Required Warnings for Cigarette Packages and Advertisements, 85 Fed. Reg. 15,638 (Mar. 18, 2020). Plaintiffs raise the following claims: (1) the warnings go beyond purely factual, uncontroversial mat- ters of the sort that the First Amendment allows the government to compel in private speech; (2) the FDA lacked statutory author- ity to change the Tobacco Control Act’s nine warnings into the rule’s eleven warnings, to change the wording of the Act’s warn- ings, or to take either step when it did; (3) the FDA’s choice of wording and graphics for the rule is arbitrary, capricious, or an abuse of discretion within the meaning of the Administrative Pro- cedure Act (APA); and (4) the FDA’s notice-and-comment pro- cess fell short of the APA’s procedural requirements. Doc. 1. The court entered summary judgment for plaintiffs on their First Amendment challenge to the rule. Doc. 106. But the Fifth Circuit reversed that judgment and remanded for this court’s con- sideration of the APA claims (which include the statutory-author- ity claims). 96 F.4th 863, 868 (5th Cir. 2024). On remand, the court has received plaintiffs’ motion for interim relief on the re- manded claims and defendants’ motion for summary judgment on them. Docs. 122, 126.

Analysis Plaintiffs argue that, absent prompt interim relief, the rule’s looming effective date will cause plaintiffs to incur costs that can- not be reimbursed (due to sovereign immunity) if plaintiffs ulti- mately prevail in a final judgment. The court credits plaintiffs’ ev- idence of those imminent, irreparable costs absent judicial relief. The court also finds that the burden to defendants of interim re- lief and the public interest do not significantly counterbalance those irreparable costs because the rule’s only goal is achieving more information in the abstract, not achieving a real-world change in behavior (an interest that the rule disclaims). So the three equitable factors bearing on issuance of a preliminary in- junction or 5 U.S.C. § 705 interim relief favor plaintiffs. The question thus reduces to whether plaintiffs have a sub- stantial likelihood of success on the merits of their pending claims. They do as to the claim of a lack of statutory authority. The court thus enters a preliminary injunction and postpones the rule’s effective date pursuant to 5 U.S.C. § 705. I. Statutory authority for the challenged rule Plaintiffs argue that the FDA lacked authority under the To- bacco Control Act to compel the warnings in the rule. The defense of res judicata does not apply to this claim. The D.C. Circuit’s 2012 decision addressed only the challengers’ First Amendment claim. R.J. Reynolds Tobacco Co. v. FDA, 696 F.3d 1205 (D.C. Cir. 2012). Moreover, the prior rule vacated there required only nine graphic warnings with the statutory text, not this rule’s eleven warnings with mostly different text. Id. at 1208. A. Statutory background The relevant statutory authority rests in 15 U.S.C. § 1333. Af- ter the Tobacco Control Act’s amendments, it reads in full: § 1333. Labeling (a) Label requirements (1) In general It shall be unlawful for any person to manu- facture, package, sell, offer to sell, distribute, or import for sale or distribution within the United States any cigarettes the package of which fails to bear, in accordance with the require- ments of this section, one of the following la- bels: WARNING: Cigarettes are addictive. WARNING: Tobacco smoke can harm your children. WARNING: Cigarettes cause fatal lung dis- 6a.8e. WARNING: Cigarettes cause cancer. WARNING: Cigarettes cause strokes and heart disease. WARNING: Smoking during pregnancy can harm your baby. WARNING: Smoking can kill you. WARNING: Tobacco smoke causes fatal lung disease in nonsmokers. WARNING: Quitting smoking now greatly re- duces serious risks to your health. (2) Placement; typography; etc. Each label statement required by paragraph (1) shall be located in the upper portion of the front and rear panels of the package, directly on the package underneath the cellophane or other clear wrapping. Each label statement shall comprise the top 50 percent of the front and rear panels of the package. The word ‘“WARN- ING" shall appear in capital letters and all text shall be in conspicuous and legible 17-point type, unless the text of the label statement would oc- cupy more than 70 percent of such area, in which case the text may be in a smaller conspicuous and legible type size, provided that at least 60 percent of such area is occupied by required text. The text shall be black on a white back- ground, or white on a black background, in a manner that contrasts, by typography, layout, or color, with all other printed material on the package, in an alternating fashion under the plan submitted under subsection (c).

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(3) Does not apply to foreign distribution The provisions of this subsection do not apply to a tobacco product manufacturer or distribu- tor of cigarettes which does not manufacture, package, or import cigarettes for sale or distri- bution within the United States. (4) Applicability to retailers A retailer of cigarettes shall not be in viola- tion of this subsection for packaging that— (4) contains a warning label; (B) is supplied to the retailer by a license- or permit-holding tobacco product manufac- turer, importer, or distributor; and (C) is not altered by the retailer in a way that is material to the requirements of this subsection. (b) Advertising requirements (1) In general It shall be unlawful for any tobacco product manufacturer, importer, distributor, or retailer of cigarettes to advertise or cause to be adver- tised within the United States any cigarette unless its advertising bears, in accordance with the requirements of this section, one of the la- bels specified in subsection (a). (2) Typography, etc. Hach label statement required by subsection (a) in cigarette advertising shall comply with the standards set forth in this paragraph. For press and poster advertisements, each such state- ment and (where applicable) any required state- ment relating to tar, nicotine, or other constit- vent (including a smoke constituent) yield shall comprise at least 20 percent of the area of the advertisement and shall appear in a conspicu- ous and prominent format and location at the top of each advertisement within the trim area. The Secretary may revise the required type siz- es in such area in such manner as the Secre- tary determines appropriate. The word ‘‘WARN- ING" shall appear in capital letters, and each label statement shall appear in conspicuous and legible type. The text of the label statement

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shall be black if the background is white and white if the background is black, under the plan submitted under subsection (c). The label state- ments shall be enclosed by a rectangular border that is the same color as the letters of the state- ments and that is the width of the first down- stroke of the capital ‘"W"’ of the word “WARN- ING’" in the label statements.

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R.J. Reynolds Tobacco Company v. United States Food And Drug Administration, Counsel Stack Legal Research, https://law.counselstack.com/opinion/rj-reynolds-tobacco-company-v-united-states-food-and-drug-administration-txed-2025.