June 12, 2014 United States Supreme Court opinions

Clark v Rameker

Clark field for bankruptcy and claimed the IRA which she inherited from her mother as an exemption under 11 USC 522(b)(3)(C). The claim was disallowed and this was ultimately upheld by the 7th Circuit. Resolving a circuit split, the Court affirmed. It held that the ordinary meaning of “retirement funds” in (b)(3)(C) means a sum of money set aside for when a person stops working. The inherited IRA here does not qualify as a person cannot put funds into the account, is required to make withdrawals even if not retired and can withdraw the entire amount without penalty. The Court held accepting Clark’s position would upset the balance the Code sets between debtor and creditor interests and would render the provision superfluous.

POM Wonderful LLC v Coca Cola, Inc.

POM sued Coca Cola under 15 USC 1125alleging misleading labeling on certain juice products. The district court ruled the suit was bared by the Food Drug and Cosmetic Act as amended and the implementing regulations. The 9th Circuit affirmed. The Court, with justice Breyer recused, reversed. It held that under the plain language of 1125, food labeling claims were authorized. Comparing the statutes, the Court held that they complement each other in that 1125 protects competitors in the market while the Act and regulations protect public health and safety. It also noted that the Food and Drug Administration is authorized to enforce the Act, but, not 1125 and Congress has chosen to prevent states from adding requirements on food labels, but, 1125 actions have not been barred. Thus, allowing the two statutes to operate as intended gives full effect to congressional intent.

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