Watson v. Philip Morris Companies, Inc.

551 U.S. 142·2007

What the Court Decided

Held that a tobacco company's compliance with federal regulations did not make it 'acting under' a federal officer for removal purposes, distinguishing mere regulation from the kind of delegation of authority contemplated by the statute.

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Cited In

Chevron USA v. Plaquemines Parish

2025 Term · 24-813

Central precedent on the meaning of 'acting under' a federal officer. Respondents relied heavily on Watson's statement that a defendant may remove only if the charged acts were committed while acting under a federal officer.