Trends In Responsible Corporate Officer Doctrine Under FDCA

Law360, New York (December 14, 2015, 1:11 PM EST) -- Roscoe C. Howard Jr.

Leasa Woods Anderson In recent years, the use of the responsible corporate officer (RCO) doctrine in federal prosecutions for violations of the Federal Food, Drug and Cosmetic Act[1] (FDCA) has resurfaced, and prosecutors are threatening even more use in the future. Before a discussion on recent cases and future trends, however, it is necessary and important to have an understanding of the history of the RCO doctrine.

The History of the RCO Doctrine

So what is the RCO doctrine and who qualifies as a responsible corporate officer? The RCO doctrine provides for the prosecution of individual corporate...

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