In 1949, federal inspectors seized dozens of cases of fruit spread manufactured by the Pure Food Manufacturing Company. The product contained only 38 percent fruit, falling short of the Federal Food, Drug, and Cosmetic Act standard requiring at least 45 percent fruit to be officially labeled as jam. However, the manufacturer had explicitly labeled the jars as Imitation Jam.
The federal government initiated an in rem legal action directly against the physical jars, arguing that calling sub-standard fruit spread imitation jam bypassed federal standards and misled consumers. The legal dispute ascended to the United States Supreme Court in 1951. Writing for the majority, Justice Felix Frankfurter ruled against the federal government.
The Court held that the product was plainly labeled as an imitation as permitted by Section 403(c) of the Act. Frankfurter reasoned that an imitation of a food product is not misbranded if it clearly bears the word imitation on its label. The ruling set a major legal precedent regarding truth-in-labeling, consumer disclosure, and statutory interpretation, establishing that accurate disclosure of a sub-standard product's nature prevents it from being legally fraudulent.