Off-Label Enforcement, Not Promotion, May See First Changes After Free Speech Ruling

In a watershed decision, a federal appeals court declares that manufacturers cannot be prosecuted under the FD&C Act’s misbranding provisions solely for speech promoting off-label use of a drug. Industry attorneys predict the decision, if it stands, will change the government’s approach to pursuing such cases.

A landmark appeals court ruling that the government cannot prosecute pharmaceutical manufacturers under the FD&C Act’s misbranding provisions solely for off-label promotion likely will reshape the FDA and Justice Department’s approach to bringing such actions but will not foreclose them, industry attorneys say.

In a 2-1 opinion issued Dec. 3, a panel of the Second Circuit U.S

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