The District Court granted summary judgment in favor of Altria, finding the state-law claim pre-empted by the Federal Cigarette Labeling and Advertising Act, 15 U.S.C.
The Court's decision was therefore meant to answer the following question: Does federal preemption of the Maine Unfair Trade Practices Act hinge on the express or implied nature of the allegedly fraudulent misrepresentations?
Justice John Paul Stevens, writing for a 5-4 Court, held that neither the Labeling Act's pre-emption provision, nor the Federal Trade Commission's actions in this field, expressly or impliedly preempt claims related to "smoking and health" under the Maine statute.
The Labeling Act's stated purposes are to inform the public of the health risks of smoking while protecting commerce and the economy from the ill effects of nonuniform requirements to the extent consistent with the first goal.
(c) Various Federal Trade Commission decisions with respect to statements of tar and nicotine content do not impliedly preempt state deceptive practices rules like the MUTPA.
Rather, he argued that the Court should adopt a clear test that expressly preempts any state law claim that "imposes an obligation...because of the effect of smoking upon health."