Featured Chrome Extensions:

Casey IRACs are produced by an AI that analyzes the opinion’s content to construct its analysis. While we strive for accuracy, the output may not be flawless. For a complete and precise understanding, please refer to the linked opinions above.

Keywords

liabilityappealcorporation
statutecorporationmisdemeanorrespondent

Related Cases

State v. Heines, 144 Fla. 272, 197 So. 787
View Case »
Banister v. United States, 715 Fed.Appx. 638, 120 A.F.T.R.2d 2017-6700, 2017-2 USTC P 50,428
View Case »
Hutchins v. Municipal Court, 61 Cal.App.3d 77, 132 Cal.Rptr. 158
View Case »
Currie v. State, 516 S.W.2d 684
View Case »
Curry v. State, 30 S.W.3d 394
View Case »
Justia Law Link
LexisNexis Link
Westlaw Link
CourtListener Link
Oyez Link

U.S. v. Dotterweich, 320 U.S. 277, 64 S.Ct. 134, 88 L.Ed. 48

Facts

Buffalo Pharmacal Company, Inc. and its president Joseph H. Dotterweich were charged with violating the Federal Food, Drug, and Cosmetic Act by shipping misbranded and adulterated drugs in interstate commerce. The company repackaged drugs under its own label after purchasing them from manufacturers. The jury found Dotterweich guilty on three counts, while the jury was deadlocked regarding the corporation's guilt.

The Company, a jobber in drugs, purchased them from their manufacturers and shipped them, repacked under its own label, in interstate commerce.

Issue

Whether the criminal sanctions of the Federal Food, Drug, and Cosmetic Act apply to a corporate officer when the corporation is also charged with violations of the Act.

Whether the criminal sanctions of the Federal Food, Drug, and Cosmetic Act of 1938 plainly and unmistakably apply to the respondent in his capacity as a corporate officer.

Rule

The Act defines 'person' to include corporations and holds individuals responsible for violations committed in the course of their duties, even if they did not have direct knowledge of the wrongdoing.

The statute (s 303) makes ‘any person’ who violates s 301(a) guilty of a ‘misdemeanor’. It specifically defines ‘person’ to include ‘corporation’. s 201(e).

Analysis

The Supreme Court analyzed the provisions of the Federal Food, Drug, and Cosmetic Act, emphasizing that the law was designed to hold individuals accountable for their roles in corporate violations. The Court noted that the Act's language did not exempt corporate officers from liability, and it rejected the argument that only the corporation could be prosecuted for violations.

The Supreme Court analyzed the provisions of the Federal Food, Drug, and Cosmetic Act, emphasizing that the law was designed to hold individuals accountable for their roles in corporate violations.

Conclusion

The Supreme Court reversed the Circuit Court of Appeals' decision, affirming Dotterweich's conviction under the Federal Food, Drug, and Cosmetic Act.

Judgment reversed.

Who won?

The government prevailed in the case, as the Supreme Court reinstated Dotterweich's conviction, affirming that corporate officers can be held liable under the Act.

The government prevailed in the case, as the Supreme Court reinstated Dotterweich's conviction, affirming that corporate officers can be held liable under the Act.

You must be