Gardner v. Toilet Goods Association case brief

Gardner v. Toilet Goods Association case brief summary
387 U.S. 167 (1967)

CASE SYNOPSIS

Defendant government sought review of a judgment of the Court of Appeals for the Second Circuit, which held that judicial review of regulations concerning what constituted a color additive was proper. The government challenged judicial review of regulations promulgated under the Color Additive Amendments of 1960, 21 U.S.C.S. §§ 321-376, and maintained that plaintiff association of companies' action should be dismissed.

CASE FACTS
The government challenged judicial review of regulations promulgated by the Commissioner of Food and Drugs to prescribe conditions for the use of color additives in foods, drugs, and cosmetics under the Color Additive Amendments of 1960, 21 U.S.C.S. §§ 321-376.

DISCUSSION

• The court held that the circuit court was correct in holding that the district court did not err when it refused to dismiss the complaint brought by an association of companies with respect to these regulations. 
• The court agreed with both lower courts that this was not a situation in which consideration of the underlying legal issues would be facilitated if they were raised in the context of a specific attempt to enforce the regulations. 
• The court agreed that the association of companies was threatened with irreparable injury by the intended consequences of the challenged regulations, and that to resort to later piecemeal resolution of the controversy in the context of individual enforcement proceedings would be costly and inefficient. 
• Thus, the court held that it found nothing in the Federal Food, Drug, and Cosmetic Act, 21 U.S.C.S. § 301 et seq., that precluded resort to the courts for pre-enforcement relief.

OUTCOME
The court affirmed the judgment of the lower court that held that the trial court had authority to review regulations of the government concerning use of color additives in consumer products challenged by an association of companies.



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