Navigating Executive Orders and DOJ Memos That Threaten Criminal Prosecution
FDA Law Blog
MAY 26, 2025
149, 158 (2014). The memos suggested use of the FDC Act to investigate and prosecute misbranding by manufacturers may have precedent, but a misbranding charge against a practitioner who uses drugs or other products in gender-affirming procedures would be subject to multiple legal challenges. Anthony List v. Driehaus , 573 U.S.
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