Young v. Community Nutrition Institute
United States Supreme Court
476 U.S. 974 (1986)

- Written by Alex Ruskell, JD
Facts
The Community Nutrition Institute (plaintiff) sued the Food and Drug Administration (FDA) (defendant), arguing that the Food, Drug, and Cosmetic Act required the FDA to promulgate regulations setting a tolerance level for toxic aflatoxin in corn. Aflatoxin was a fungus treated as an added substance under the act. However, the FDA had only set an action level for aflatoxin, which assured corn producers that the FDA would not seek regulatory action so long as any aflatoxin was under a certain amount. The relevant statutory language stated, “the Secretary shall promulgate regulations limiting the quantity [of toxic substances] to such extent as he finds necessary for the protection of public health.” The Institute argued that the statute made regulations mandatory, although the FDA interpreted it to mean that it only had to promulgate regulations if the FDA found it necessary to do so. The district court ruled in favor of the FDA, and the court of appeals reversed. The United States Supreme Court granted cert.
Rule of Law
Issue
Holding and Reasoning (O’Connor, J.)
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