The case arose on a libel, that is, an in rem condemnation action filed by the government to seize the jam for being in violation of federal law.
[1] The jars were assorted flavors of grape, strawberry, apricot, plum, peach and blackberry, and "contained 55% sugar, 25% fruit and 20% of a water solution of pectin.
"[4] In construing the Food, Drug, and Cosmetic Act, the court considered the legislative history of the FDCA, and determined that "its purpose was not confined to a requirement of truthful and informative labeling," but rather that Congress intended to forbid deviation, labels notwithstanding, where the Administrator had prescribed "a definition and standard of identity" for a food.
Judge Pickett dissented, finding in the FDCA a Congressional intent "to permit on the market a wholesome and nutritious food which is within the means of a great mass of our people who are unable to purchase the standard products," so long as such an imitation is properly labeled under § 343(c).
Although the purpose of the FDCA was to protect the health of those who "are largely beyond self-protection" in a world of industrially produced and mass-marketed food,[11] the issue in this case: is to construe what Congress has written.
"[14] The Court continued: In our anxiety to effectuate the congressional purpose of protecting the public, we must take care not to extend the scope of the statute beyond the point where Congress indicated it would stop.
[17] 62 Cases of Jam was significant both for its main holding about the scope of the Federal Food, Drug, and Cosmetic Act and for its reliance on an "ordinary speech" interpretation of the statute.
Judge Pickett of the Tenth Circuit had expressed his fear that the government's view of the FDCA would allow the Federal Security Administrator "absolute control over the ingredient" of all foods for which he issued a regulation.
It will remove from the market a nutritious and wholesome food which sells for approximately one-half the price of standard product.