Nunnally v. R.J. Reynolds Tobacco Company

In an action against a tobacco company alleging wrongful death resulting from lung cancer caused by the defective and unreasonably dangerous nature of cigarettes, the widow of a deceased smoker appealed the trial court's denial of her motion to set aside the jury verdict in the defendant's favor. The Supreme Court of Mississippi affirmed the trial court's denial of the motion, finding that the products liability claim of design defect was unsupported by plaintiff's evidence. The Court further found, among other things, that the trial court appropriately refused to specifically instruct the jury as to negligence, and that the trial court properly excluded evidence demonstrating the defendant's disregard of scientific reports linking cigarette smoking to cancer.

Nunnally v. R.J. Reynolds Tobacco Company, 869 So.2d 373, Supreme Court of Mississippi (2004).

  • United States
  • Mar 25, 2004
  • Supreme Court of Mississippi
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Parties

Plaintiff Kay T. Nunnally, individually and on behalf of all wrongful death beneficiaries of Joseph Lee Nunnally, deceased

Defendant R.J. Reynolds Tobacco Company

Legislation Cited

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"First, we consider plaintiff’s negligent design claim. Our holding in Estate of Hunter v. General Motors Corp., 729 So.2d 1264 (Miss. 1999), is directly on point. In Hunter, the trial court refused to accept the plaintiff's requested negligence instruction. Instead, the court gave an instruction based on the risk-utility test set out in Prestage, just as the trial judge did here. In Hunter, we relied on United States v. Carroll Towing Co., 159 F.2d 169, 173 (2d Cir. 1947), for the proposition that "[t]he risk-utility balancing test is merely a detailed version of Judge Learned Hand's negligence calculus." 729 So.2d at 1277. "As a commonsense matter, the jury weighs competing factors presented in evidence and reaches a conclusion about the judgment or decision (i.e., conduct) of the manufacturer. The underlying negligence calculus is inescapable." Hunter, 729 So.2d at 1277. "An examination of the riskutility [sic] test establishes that the test is essentially a negligence test, and [there was]....no error in failing to grant a negligence instruction in addition to the risk-utility test." Id. at 1278. Because Hunter controls the case at hand, we find that the trial court did not err when it refused to submit a negligence instruction in addition to the Prestage-based instruction."