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The Supreme Court 4/27/05 clarified the extent of federal preemption stemming from the Federal Insecticide, Fungicide and Rodenticide Act ("FIFRA"), 7 U.S.C. § 136. FIFRA, which regulates the use, sale and labeling of pesticides, provides that States "shall not impose or continue in effect any requirements for labeling of packaging in addition to or different from those required under this [Act]." The Court held that "[r]ules that require manufacturers to design reasonably safe products, to use due care in conducting appropriate testing of their products, to market products free of manufacturing defects, and to honor their express warranties or other contractual commitments plainly do not qualify as requirements for "labeling or packaging," even if those rules might induce manufacturers to alter product lables. Thus, FIFRA does not pre-empt a group of Texas peanut farmers' state law claims against a pesticide manufacturer for defective design, defective manufacture, negligent testing, and breach of express warranty. In contrast, the Court also concluded that "petitioners' fraud and negligent failure-to-warn claims are premised on common-law rules that qualify as "requirements for labeling or packaging." FIFRA therefore pre-empts those claims unless the corresponding requirements are equivalent to, and fully consistent with, FIFRA's labeling standards - a question to be resolved on remand. This decision is important to any business that is subject to FIFRA.

Decision Below: 332 F.3d 323 (5th Cir. 2003).