Dahlia Rin, an associate in the the firm’s Government Enforcement and White Collar Defense practice group, and John P. Pucci co-authored “The Misinterpretation of the Park Doctrine as Creating Strict Liability” in the November/December 2011 issue of the Food and Drug Law Institute’s Update Magazine. The article discusses the controversial issue of the U.S. Department of Justice’s and Food and Drug Administration’s recent interpretations of the Park Doctrine as creating strict liability. The Park Doctrine allows for prosecutions against corporate officers absent any proof of knowledge or intent to commit a violation under the Food, Drug, and Cosmetic Act.
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