A GUIDE TO LEGAL CASE BRIEFS

A GUIDE TO LEGAL CASE BRIEFS
I. TITLE/ CITATION
Warner-Lambert Company v. United States
U.S. Court of Appeals for the Federal Circuit
425 F.3d 1381 (2005)
II. THE FACTS
A. Material
• Warner-Lambert imports and sells lozenges in packages under the name "Halls DefenseTM Vitamin C Supplement Drops." Each drop contains daily requirement of Vitamin C, but the drops are composed primarily of sugar and glucose syrup, which together constitute more than 95 percent of each drop. Vitamin C constitutes just under 2 percent of each drop, with the remaining small percentage consisting of citric acid, flavors and color.
• Customs Serviced revoked the previous duty-free status of the vitamin C supplement drops as medicaments and reclassified them to dutiable status as sugar confectionery, resulting in the drops being subject to a duty of 6.1 percent.
B. Legal
• Warner-Lambert sued the Court of International Trade. Customs service appealed and their reclassification was upheld.
• In a six page detailed letter ruling, Customs explained the reasons for its action. Customs stated that its prior classification of the drops was "based upon the belief that Vitamin C imparted therapeutic or prophylactic character to the merchandise," but that "additional research indicates that Vitamin C has not been shown in the U.S. to have substances which imbue it with therapeutic or prophylactic properties or uses."
III. LEGAL ISSUES
A. Specific
• The issue is the validity of the reclassification by the United States Customs Service of imported Vitamin C supplement drops from their previous duty-free status as "medicaments" to dutiable status as "sugar confectionery." The Court of International Trade upheld the reclassification.
• The imported merchandise is not marketed as preventing or curing any disease.
B. General
• If the principal use of the drops were to prevent or cure disease, one would expect that their merchandising would stress that fact.

IV. THE HOLDING
• The Court of International Trade upheld the reclassification. The court ruled that the drops were not marketed to prevent or cure disease, but to provide users with their requirement of vitamin C
• The concluded that although the merchandise “mat possess medical properties, it is being marketed as much for its flavor as for its medical value. Thus it cannot be said that this merchandise is suitable only for medical purposes.
V. LEGAL RATIONALE
• Warner-Lambert failed to satisfy its liability of proving that the principal use of its Halls drops corresponds to their therapeutic or prophylactic properties
• If a statute is ambiguous and if the implementing agency’s construction is reasonable, the federal court must accept the agency’s construction of the statue, even if the agency’s reading differs from what the court believes is the best statutory interpretation.
• This case demonstrated the interpretive rule because even if the federal court disagrees with the construction of the agency’s statute and has another view on the best interpretation, the court must accept it
VI. QUESTIONS
• Although the revoking of the drops as medicaments was appropriate, since the drops have medical properties does the reclassification of the vitamin C drops as sugar confectionary truly represent the drops’ true classification?