Pom Wonderful LLC v. Coca-cola Co. (573 U.S. 102)
U.S. Supreme Court · decided June 12, 2014 · Supreme Court Database (Spaeth)
- Citation
- 573 U.S. 102 · 134 S. Ct. 2228
- Decided
- June 12, 2014
- Term
- October Term 2013
- Vote
- 8–0
- Majority author
- Justice Kennedy
- Issue area
- Economic Activity
- Disposition
- Reversed and remanded
- Outcome
- Petitioning party won
- Ideological direction
- Liberal
Opinion excerpt
Justice KENNEDY delivered the opinion of the Court. POM Wonderful LLC makes and sells pomegranate juice products, including a pomegranate-blueberry juice blend. App. 23a. One of POM's competitors is the Coca-Cola Company. Coca-Cola's Minute Maid Division makes a juice blend sold with a label that, in describing the contents, displays the words "pomegranate blueberry" with far more prominence than other words on the label that show the juice to be a blend of five juices. In truth, the Coca-Cola product contains but 0.3% pomegranate juice and 0.2% blueberry juice. Alleging that the use of that label is deceptive and misleading, POM sued Coca-Cola under § 43 of the Lanham Act. 60 Stat. 441, as amended, 15 U.S.C. § 1125. That provision allows one competitor to sue another if it alleges unfair competition arising from false or misleading product descriptions. The Court of Appeals for the Ninth Circuit held that, in the realm of labeling for food and beverages, a Lanham Act claim like POM's is precluded by a second federal statute. The second statute is the Federal Food, Drug, and Cosmetic Act (FDCA), which forbids the misbranding of food, including by means of false or misleading labeling. §§ 301, 403, 52 Stat. 1042, 1047, as amended, 21 U.S.C. §§ 331, 343. The ruling that POM's Lanham Act cause of action is precluded by the FDCA was incorrect. There is no statutory text or…
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