United States v. An Article … “Hubbard Electrometer”
United States District Court for the District of Columbia
333 F. Supp. 357 (1971)

- Written by Mary Phelan D'Isa, JD
Facts
In 1962, the Food and Drug Administration seized more than 100 E-meters and 200 pieces of literature from the Founding Church of Scientology (the church), claiming the E-meter was a device under the Food, Drug, and Cosmetic Act (FDCA) and alleging misbranding and inadequate labeling. The E-meters were held out in the literature as auditing devices and represented as being able to cure many physical and mental illnesses when used in religious as well as secular auditing sessions. The FDA sought to condemn both secular and religious uses of the E-meters, requiring the court to reconcile the FDCA’s misbranding requirements and the Frist Amendment protections for religious institutions and beliefs from governmental interference under the First Amendment.
Rule of Law
Issue
Holding and Reasoning (Gesell, J.)
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