R.J. Reynolds Tobacco Co. v. Seattle-King County Department of Health, et al.

A cigarette manufacturer brought an action against local governments claiming that city and county ordinances prohibiting the distribution of free tobacco products and samples were preempted by the Federal Cigarette Labeling and Advertising Act (FCLAA).  The Court noted that the FCLAA regulated several aspects of cigarette advertising and labeling and explicitly barred state governments from regulating the promotion of cigarettes labeled in conformity with the act.  The Court denied the State of Washington's motion to intervene to enforce a provision of an agreement between the state and the manufacturer that prohibited facial challenges to existing local legislation, noting that the challenge was not facial but concerned the application of the ordinances to the distribution of cigarettes.  Additionally, the Court held that the distribution of free products constituted promotional activities and that the FCLAA therefore preempted the local ordinances' restrictions on the distribution of cigarette products and samples.

R.J. Reynolds Tobacco Co. v. Seattle-King County Department of Health, 473 F. Supp. 2d 1105 (W.D. Wash. 2007).

  • United States
  • Feb 6, 2007
  • United States District Court for the Western District of Washington, at Seattle
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Parties

Plaintiff R.J. Reynolds Tobacco Company

Defendant

  • Others
  • Seattle-King County Department of Health

Third Party

  • State of Washington

Legislation Cited

Federal Cigarette Labeling and Advertising Act (as amended), 15 USC §§ 1331 - 1341

Federal Cigarette Labeling and Advertising Act ("FCLAA"), 15 U.S. Code Section 1331, et seq.

King County Board of Health Code ("BHC") Section 19.04.115

Seattle Municipal Code ("SMC") 6.240.120

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"Three federal courts, including this one, have already determined that cigarette sampling is a form of promotion, and, therefore, state laws regulating such sampling, are prohibited. R.J. Reynolds Tobacco Co. v. McKenna, 445 F.Supp.2d 1252 (W.D.Wash.2006); Jones v. Vilsack, 272 F.3d 1030 (8th Cir.2001); Rockwood v. City of Burlington, 21 F.Supp.2d 411 (D.Vt.1998). In Jones, the Eighth Circuit Court of Appeals concluded that sampling "naturally falls within the range of meaning ordinarily attributed to the term `promotion,' so sampling is a form of cigarette "promotion" under the FCLAA. Jones, 272. F.3d at 1035-37. Similarly, the United States District Court for the District of Vermont concluded that a ban on sampling cigarettes fell into the purview of the FCLAA and was therefore preempted. Rockwood, 21 F.Supp.2d at 420. This Court was persuaded by those conclusions, and also determined that cigarette sampling is a form of "promotion" under the FCLAA. McKenna, 445 F.Supp.2d at 1257. Defendants ask this Court to reject the reasoning of McKenna, Jones and Rockwood because the courts ignored the presumption against preemption of traditional state police power regulations and neglected to consider the FCLAA's contextual framework to determine the preemptive scope of section 1334(b). However, this Court is not persuaded by defendants' arguments. First, this Court agrees that the plain and ordinary meaning of "promotion" includes product sampling. While defendants take issue with Judge Burgess's and the Eighth Circuit's reliance on dictionary definitions of promotion, the reliance on such definitions is standard practice. See, e.g., United States v. Mohrbacher, 182 F.3d 1041, 1048 (9th Cir.1999) (explaining that when there is no indication that Congress intended a specific legal meaning for the term, the court may look to sources such as dictionaries for a definition). Likewise, there is no clearly expressed intent in the legislative history contrary to that meaning. See S & M Inv. Co. v. Tahoe Regional Planning Agency, 911 F.2d 324, 327 (9th Cir.1990)."