Watson v. Philip Morris

Two individuals brought an action against a cigarette manufacturer in an Arkansas state court under Arkansas state business practices laws, claiming that the manufacturer had misled consumers by deceptively manipulating its "lights" cigarettes to register a lower content of tar and nicotine on the Cambridge Filter Method (CFM) test than that actually consumed by smokers when using its product.  The defendant moved to remove the case to federal court, arguing that because the Federal Trade Commission had approved the CFM as a manner of testing cigarette content, the manufacturer "act[ed] under" an "agency" or "officer" of the United States when testing cigarettes using the CFM, thus fulfilling the conditions for removal detailed in federal statutory law.  The Court held that removal was improper, finding that the language of the statute required not merely complying with administrative regulations but "assist[ing]" with or "carry[ing] out" the implementation of the law.


Watson, et al. v. Philip Morris Cos., Inc., et al., 551 U.S. 142, Supreme Court of the United States (2007).

  • United States
  • Jun 11, 2007
  • Supreme Court of the United States



  • Lisa Watson
  • Loretta Lawson


  • Others
  • Philip Morris Companies, Inc.

Legislation Cited

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Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product