United States v. Article of Drug Labeled Decholin

264 F. Supp. 473, 1967 U.S. Dist. LEXIS 11366
CourtDistrict Court, E.D. Michigan
DecidedFebruary 10, 1967
DocketCiv. A. 24029
StatusPublished
Cited by5 cases

This text of 264 F. Supp. 473 (United States v. Article of Drug Labeled Decholin) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Article of Drug Labeled Decholin, 264 F. Supp. 473, 1967 U.S. Dist. LEXIS 11366 (E.D. Mich. 1967).

Opinion

OPINION

FREEMAN, District Judge.

These cross motions for summary judgment, pressed by the United States and the claimant, present significant questions of first impression under the 1951 amendment to the Federal Food, Drug and Cosmetic Act.

*475 The Government commenced the case by filing a libel of information for condemnation of seventy-three packages bearing appproximately ten thousand tablets, each of which contained 250 milligrams (3% grains) of dehydrocholic acid and was marketed under the trade name “Decholin.” Ames Company, Inc., the manufacturer of Decholin, intervened in this in rem proceeding as claimant of the seized articles. 1

The action is predicated upon Federal Food, Drug and Cosmetic Act, § 304, as amended, 21 U.S.C. § 334, providing:

“Any article of food, drug, device, or cosmetic that is adulterated or mis-branded when introduced into or while in interstate commerce or while held for sale (whether or not the first sale) after shipment in interstate commerce * * * shall be liable to be proceeded against while in interstate commerce, or at any time thereafter, on libel of information and condemned in any district court of the United States within the jurisdiction of which the article is found * *

The only substantive provision of concern is Federal Food, Drug and Cosmetic Act, § 503, as amended, 21 U.S.C. § 353, reading in pertinent part:

“(b) (1) A drug intended for use by man which—

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(B) because of its toxicity or other potentiality for harmful effect, or the method of its use, or the collateral measures necessary to its use; is not safe for use except under the supervision of a practitioner licensed by law to administer such drug * * *

(C) * * * shall be dispensed only (i) upon a written prescription of a practitioner licensed by law to administer such drug, or (ii) upon an oral prescription of such practitioner which is reduced promptly to writ-mg and filed by the pharmacist, or (iii) by refilling any such written or oral prescription if such refilling is authorized by the prescriber either in the original prescription or by oral order which is reduced promptly to writing and filed by the pharmacist.

* * *

(4) A drug which is subject to paragraph (1) of this subsection shall be deemed to be misbranded if at any time prior to dispensing its label fails to bear the statement ‘Caution: Federal law prohibits dispensing without prescription’. A drug to which paragraph (1) of this subsection does not apply shall be deemed to be misbranded if at any time prior to dispensing its label bears the caution statement quoted in the preceding sentence.”

It is agreed that Decholin is a drug within the meaning of the Act and that the seized tablets had moved in interstate commerce. It is also undisputed that the labels on the libeled packages give no indication that Decholin may not lawfully be dispensed without prescription. The precise legal consideration raised by these motions is whether amended section 503 causes Decholin to be misbranded because its containers fail to carry such a precautionary statement.

Since the Decholin label is the center of this controversy, its material contents are set forth at this point. The printed matter on one side of each of the seized packages reads insofar as relevant:

“Decholin Brand

Dehydrocholic Acid, Ames

250 mg. (3% gr.) contained in each tablet.”

The reverse side of the containers gives this additional information:

“INDICATIONS

“Indigestion . . . after-meal discomfort and fullness (particularly after *476 fatty meals) . . . excessive belching . . . constipation.

“AVERAGE ADULT DOSE:

“One or two tablets, three times daily or as directed by physician.

“CAUTION:

“Consult your physician should symptoms persist or severe abdominal pain, nausea and vomiting appear.

“KEEP THIS AND ALL MEDICATIONS OUT OF THE REACH OF CHILDREN.”

In support of its request for summary judgment, each movant relies almost exclusively upon a number of affidavits which it has procured. These include the statements of qualified physicians specializing in gastroenterology, several of whom are on the faculties of leading medical schools, relative to whether harm can come to a layman who, without consulting a medical practitioner, takes De-cholin for relief of the indicative symptoms listed above. The claimant also calls attention to the fact that, in answer to claimant’s interrogatories, the United States has admitted that it is unaware of any actual case in which a layman was injured under these circumstances.

There is only one fundamental issue presented by these motions: is Decholin unsafe as a drug intended for human use without a prescription? Nevertheless, recognizing that in section 503(b) (1) (B) Congress listed a number of ostensibly different reasons why a drug may be unsafe for self-medication and attempting to deal with the parties’ arguments in an organized fashion, the motions will be viewed as raising two issues. First, is the pharmacological effect of Decholin such that, unless it is taken pursuant to and in accordance with a physician’s directions, reactions sufficient to cause the product to be unsafe may result from its ingestion? This will be called the “toxicity question.” 2 Second, does the fact that Decholin may be taken by a person who, although experiencing the indications set out on the label, has an ailment which Decholin cannot cure, coupled with the fact such an individual may postpone a visit to his physician in reliance upon the over-the-counter availability of Decholin, cause the drug to be unsafe? Because the gist of the Government’s argument on this issue is that an immediate professional diagnosis to detect the underlying cause of the symptoms in a particular case is a step which must precede or accompany use in order for the drug to be considered safe, this point will be called the collateral measures question. Unfortunately, some of the subissues and contentions underlying each of these two topics are so similar that the effort to pinpoint two distinct inquiries will not be totally successful.

At the basis of both questions lies the fact that the indications mentioned on the Decholin container can stem from any one of what, for present purposes, will be considered as three types of causes: biliary tract obstruction, organic disease and various minor factors. These last include a host of elements ranging from pregnancy through dietary indiscretions, such as skipping meals, and on to old age. Claimant willingly agrees with the Government that Decholin would not be prescribed by a physician to cure either a tract obstruction or an organic disease.

Toxicity Question

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Related

United States v. General Nutrition, Inc.
638 F. Supp. 556 (W.D. New York, 1986)
National Nutritional Foods Ass'n v. Weinberger
512 F.2d 688 (Second Circuit, 1975)
National Nutritional Foods Association v. Weinberger
512 F.2d 688 (Second Circuit, 1975)
Bentex Pharmaceuticals, Inc. v. Richardson
463 F.2d 363 (Fourth Circuit, 1972)

Cite This Page — Counsel Stack

Bluebook (online)
264 F. Supp. 473, 1967 U.S. Dist. LEXIS 11366, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-article-of-drug-labeled-decholin-mied-1967.