New York Gen. Bus. Law §391-oo restricts the sale of certain dietary supplements used for weight loss and muscle building to minors. Seeking to prevent the Statute’s enforcement, nonprofit trade organization National Products Association (NPA) sued the New York Attorney General’s office, in her official capacity.

Denying NPA a preliminary injunction, U.S. District Judge Joan Azrack of the Eastern District of New York dismissed suit for lack of subject-matter jurisdiction, finding the group failed to establish Article III standing.