P&G Sheds ZzzQuil ‘Non-Habit Forming’ Deception Class Action

Consumers alleging Proctor & Gamble Co. deceptively advertised ZzzQuil sleep aid products as “non-habit forming” didn’t include enough support for their claims, a federal judge said.

“None of the articles cited” in the consumers’ complaint supported their argument that the use of diphenhydramine hydrochloride—an antihistamine that can cause drowsiness—is habit-forming, the US District Court for the Northern District of California said Monday.

Only one source, an article from Consumer Reports that referenced a 2008 study on rats, showed diphenhydramine might be capable of causing habit formation, the court said.

“Simply put, Plaintiffs cannot allege that P&G has made false or ...