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Year on year it fails to bring in the projected funds from excise duties, creating a lucrative market for criminals to thrive and failing hard working retailers from earning an honest living

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In his comment to the FDA on Section 911, prominent public health scholar Stanton Glantz warned that modified risk products have a strong potential for simply being the latest chapter in [tobacco companies] fraud. This article is the first to analyze the heretofore unanswered question: what is the scope of constitutional preemption when Section 911 (modified risk tobacco products) and Section 916 (preemption of state law) are read together against the broader background of U.S