Fool Me Once, Shame on You. Fool Me Twice and It’s a Federal Felony—Always?
FDA Law Blog
SEPTEMBER 28, 2023
Walsh — As readers of the FDA Law Blog know, the FDC Act is a strict liability criminal enforcement statute that can impose criminal misdemeanor penalties on a person without any showing of intent. Richard Marschall, a “naturopathic doctor,” had been convicted in 2017 for a misdemeanor violation of the FDC Act for selling misbranded drugs.
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