Cipollone v. Liggett Group
Citation
505 U.S. 504 (1992)
Facts
The estate of Rose Cipollone, a long-time smoker who died of lung cancer, sued several cigarette manufacturers for failure to warn and other state-law claims. The manufacturers argued that the Federal Cigarette Labeling and Advertising Act preempted all state claims related to cigarette advertising and promotion.
Issue
Whether the Federal Cigarette Labeling and Advertising Act preempts state common law damages actions by smokers against cigarette manufacturers.
Holding
The Court found partial preemption: the Act preempts some but not all of the plaintiff’s claims, depending on whether the claim would impose an obligation different from the federal requirements.
Rule
Express preemption provisions should be narrowly construed; only claims that impose obligations different from federal requirements are preempted, while claims that are equivalent to federal requirements may proceed.