POM Wonderful LLC v. Coca-Cola Co.
The Supreme Court ruled that a juice maker can sue a rival under the federal false-advertising law over a misleading pomegranate-blueberry juice label, even though the label also complies with separate federal food-labeling rules.
The decision means businesses can use competitor lawsuits as a tool to police misleading labels even in industries with detailed federal safety regulation, because the Court found the two federal laws work together rather than one blocking the other.
“An agency may not reorder federal statutory rights without congressional authorization.”
The Court rejects the idea that FDA regulations alone can block a separate federal lawsuit.
How it got here: A federal trial court sided with Coca-Cola on summary judgment, the Ninth Circuit affirmed, and POM asked the Supreme Court to review the case.
The Case in Depth
What happened
POM Wonderful sells pomegranate juice products, including a pomegranate-blueberry blend. Coca-Cola's Minute Maid division sold a juice blend labeled "pomegranate blueberry" in large letters, though it was 99.4% apple and grape juice and contained only trace amounts of pomegranate and blueberry juice. POM sued Coca-Cola under a federal unfair-competition law, claiming the label deceived consumers and cost POM sales.
The question before the Court
Could a juice company sue a competitor under a false-advertising law over a misleading juice label, even though the label was also regulated by federal food safety rules?
The Court's answer
Yes — the Court ruled that POM could sue Coca-Cola under the federal unfair-competition law over its juice label, even though that label also complied with separate federal food-safety labeling rules. Nothing in either law's text says one blocks the other, and the two laws serve different purposes: the food-safety law protects public health, while the unfair-competition law protects businesses from deceptive rivals.
The Court also rejected the government's proposed compromise, which would have barred lawsuits only over label features specifically authorized by food-safety regulators. Since the regulators never weighed the competing interests protected by the unfair-competition law when writing those rules, letting them silently override that law would improperly let an agency rewrite Congress's scheme without its permission.
Curious how the Court got there? See the step-by-step legal reasoning →
Why it matters
Companies competing in regulated industries like food and beverages retain the ability to sue rivals over deceptive labeling, even when a federal agency also regulates that labeling. This gives businesses an added enforcement tool beyond what the regulating agency chooses to pursue, and it may lead to more competitor lawsuits challenging product labels nationwide.
What changes now
The case returns to the lower courts, where POM's unfair-competition lawsuit against Coca-Cola over the juice label can proceed on the merits. This is a final ruling on the legal question of whether such lawsuits are allowed at all; it does not decide whether Coca-Cola's label actually violated the law, which will be litigated on remand.
What this does not decide
The Court did not decide whether Coca-Cola's label actually misled consumers or violated the unfair-competition law -- only that such a lawsuit is not automatically blocked by food-labeling regulations. That underlying question returns to the lower courts.
How the Court got there
The legal reasoning, step by step
- The Court first clarified this was not a preemption case, since preemption asks whether federal law displaces state law, while this case asked whether one federal law (food safety rules) blocks a private lawsuit under another federal law (the unfair-competition statute).
- The Court treated the dispute as a matter of statutory interpretation, examining the text and structure of both federal laws rather than any presumption against overlap between them.
- Neither law contained language forbidding or limiting competitor lawsuits over labels also covered by food-labeling rules, and the absence of such language over seven decades of the laws coexisting was strong evidence Congress did not mean for food-safety regulation to be the exclusive check on labeling.
- The Court noted that the food-safety law expressly preempted only certain state labeling laws, not federal ones, suggesting Congress meant to leave other federal remedies like competitor lawsuits intact.
- Because the two federal laws serve different purposes -- one protecting public health, the other protecting fair competition among businesses -- and impose different remedies, the Court found they complement rather than conflict with each other.
- The Court rejected the federal government's proposed middle-ground rule that would block lawsuits over label features specifically authorized by agency regulation, since the underlying regulatory rulemaking never considered or accounted for the unfair-competition law's separate protections.