Pharmaceutical Research & Manufacturers of America v. John McCuskey

Circuit 4Mar 31, 2026

Split Score

SplitScore: 62/100

Case Summary

Disposition

Affirmed

The Fourth Circuit upheld a preliminary injunction blocking enforcement of West Virginia’s S.B. 325, a law that forces drug manufacturers in the federal 340B program to supply discounted drugs to any contract pharmacy used by a covered entity. The court ruled that the statute is likely pre-empted because it impermissibly alters Congress’s 340B bargain and intrudes into a field reserved for federal regulation, satisfying the Winter factors for injunctive relief.

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Circuit Split Identified

Legal Issue

Whether state statutes that compel drug manufacturers participating in the federal 340B program to deliver discounted drugs to an unlimited number of contract pharmacies are pre-empted by 42 U.S.C. § 256b under the Supremacy Clause.

Circuit Positions

Circuit 4(this circuit)

State laws mandating delivery of 340B drugs to contract pharmacies are pre-empted by federal law.

Circuit 5Circuit 8

State laws regulating delivery of 340B drugs are not pre-empted because § 340B is silent on delivery and does not occupy the field.

Conflict Summary

The Fourth Circuit holds that § 340B occupies the field and/or conflicts with state attempts to add delivery obligations, so such statutes are pre-empted. The Fifth and Eighth Circuits conclude that § 340B is silent on delivery, leaving room for state regulation; therefore the same kinds of state laws are not pre-empted.

Parties & Counsel

Parties

Appellant:John B. McCuskey, West Virginia Attorney General, et al. (state officials)
Appellee:Pharmaceutical Research and Manufacturers of America; AbbVie Inc. and related entities; Novartis Pharmaceuticals Corporation

Legal Counsel

Appellant:Caleb B. David, Office of the Attorney General of West Virginia
Appellee:Philip J. Perry, Latham & Watkins LLP; Jessica Lynn Ellsworth, Hogan Lovells US LLP; Matthew Scott Owen, Kirkland & Ellis LLP