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Judge Leon applied strict scrutiny to the warning labels, meaning that the FDA had to show that its rule was narrowly tailored to achieve a compelling government interest. He applied this standard because the warning labels are compelled speech of not simply purely factual and uncontroversial information. The court said that if the mandated disclosure had been only of factual and uncontroversial information, then it would have been subjected only to the reasonable relationship test set out in the Supreme Courts Zauderer decision

About 150 cities and counties have placed some sort of restriction on the sale of menthol cigarettes, most issuing an outright ban