(CN) – The 3rd Circuit reinstated a class action accusing Snapple of deceptively labeling its drinks as “all natural,” when they contain high-fructose corn syrup and other artificial ingredients.
Snapple customer Stacy Holk said she paid $1.09 each for two Snapple drinks in 2007, believing they contained all-natural fruit juices. In a class action in New Jersey Superior Court, she claimed that the “all natural” labels were misleading, and that Snapple deceptively named its drinks, calling one Acai Blackberry Juice, even though it contained neither blackberry juice nor acai juice.
Snapple removed the case to federal court, where Holk was forced to whittle down her claims to just one: that the drinks aren’t “all natural,” as Snapple claims on the label.
In dismissing the case, the district court held that while Congress did not explicitly preempt state labeling laws with the Federal Food, Drug and Cosmetic Act (FDCA) and the Nutrition Labeling and Education Act (NLEA), it “impliedly preempted” them. “[P]ermitting states … to impose additional limitations and requirements on beverage labels,” the lower court explained, “would create obstacles to the accomplishment Congress’s objectives.”
Holk appealed, successfully, to the Philadelphia-based appeals court.
The 3rd Circuit didn’t buy Snapple’s argument that the FDA has established “exhaustive” regulations, particularly of juice products, through the FDCA. Snapple also claimed that the FDA deems high-fructose corn syrup “natural.”
But this policy statement on the term “natural” doesn’t preempt the plaintiffs’ claims, the appeals court concluded. It saw no reason to apply preemption – express or implied.
Congress never stated the intent to preempt state regulations, Judge Smith explained. The court also cited a “presumption against preemption” and Supreme Court precedent in reversing dismissal of the case.