Context:
– Harvey Washington Wiley led the Bureau of Chemistry when the Pure Food and Drug Act was passed in 1906.
– The Bureau prosecuted companies selling harmful products and making misleading claims.
– Coca-Cola had stopped using coca leaves and dropped headache-curing claims by 1903.
– Caffeine in Coca-Cola was increased, worrying Wiley about its harm, especially to children.
– In 1909, 40 barrels and 20 kegs of Coca-Cola were seized by Wiley.
Claim:
– The government tried to force Coca-Cola to remove caffeine under the 1906 Pure Food and Drug Act.
– Allegations included adulteration due to added caffeine making the product harmful.
– The government claimed an 8oz serving had 78.4mg of caffeine.
– Misbranding was alleged due to the absence of coca and cola in the product despite their representation.
– Labels at the time showed images of coca leaves and kola nuts.
Title:
– The case was titled against the object, not the Coca-Cola Company, using jurisdiction in rem.
– Forty Barrels and Twenty Kegs of Coca-Cola were seized by the government in 1909.
– The food itself was the subject of the case indirectly involving the company.
– The case was about the barrels and kegs seized, not directly about the company.
Decision:
– Justice Hughes delivered the decision regarding adulteration, stating caffeine was an added ingredient.
– The removal of harmful ingredients did not constitute adulteration.
– The misbranding charge was not proven by either the government or the Coca-Cola Company.
– The issue of whether the product contained coca or cola was left unsettled.
– The case was sent back to the lower court for retrial on factual matters.
Effect:
– In 1912, two bills were introduced to amend the Pure Food and Drug Act to regulate caffeine.
– The government appealed twice, winning in 1916 due to evidence on caffeine toxicity.
– Coca-Cola reduced caffeine voluntarily and settled to avoid further litigation.
– The settlement was accepted as the pressure against Coca-Cola decreased.
– Wiley’s resignation in 1912 led to the end of FDA’s interest in pursuing the case.