Pearson v. Philip Morris, Inc.

Buyers of Marlboro Lights cigarettes sued Philip Morris arguing that the company misrepresented whether Marlboro Lights had lower tar and nicotine levels between 1971 and 2000. The individuals asked for class action status to sue the company under the Oregon Unlawful Trade Practices Act. In this decision, the court of appeals overturned an earlier decision by the trial court. The appeals court said that it would be possible for the case to proceed as a class action because there are a number of common issues among the class members. The court also found that the trial court made a mistake in ruling that federal law preempted the plaintiffs’ claim. The appeals court sent the case back to the trial court asking the court to reassess whether a class action is the best method for deciding the case and, if not, if there are common issues that can be tried together in what is known as an “issue class.”

Pearson v. Philip Morris, Inc., 257 Or. App. 106 (2013).

  • United States
  • Jun 19, 2013
  • Court of Appeals, State of Oregon
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Parties

Plaintiff

  • Laura Grandin
  • Marilyn C. Pearson
  • Other similarly situated people

Defendant

  • Philip Morris Companies, Inc. (aka Altria Group, Inc.)
  • Philip Morris, Inc. (aka Philip Morris USA, Inc.)

Legislation Cited

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"As to plaintiffs’ third assignment of error, the trial court’s denial of plaintiffs’ request for certification of an issue class was based on its conclusion that all three elements of plaintiffs’ claims required individual inquiries. Because that conclusion was erroneous, if the trial court determines that an issue class covering questions of liability would be superior to treatment of the entire case as a class action, it must reconsider plaintiffs’ motion for certification of an issue class."
"As to plaintiffs’ second assignment of error, we conclude that (1) to prove damages—viz., that they and the putative class members have suffered ascertainable losses—plaintiffs would have to prove that the Marlboro Lights that they and the putative class members purchased were not inherently light and that the missing feature had value; (2) whether plaintiffs and the putative class members have suffered ascertainable losses can be litigated on a class-wide basis; (3) to prove causation—viz., that they and the putative class members have suffered ascertainable losses “as a result of” defendant’s representations—plaintiffs would have to prove that they and the putative class members relied on the representations; (4) whether plaintiffs and the putative class members relied on the representations can be litigated on a class-wide basis; (5) because all of the elements of liability can be proved on a common basis, the trial court erred in concluding that common questions would not predominate over individual questions; (6) the trial court’s conclusion that a single class action would not be superior to other available methods for adjudicating the controversy was premised on a legal error; and, therefore, (7) we must remand in order for the trial court to reconsider whether a class action is superior to other methods of litigating the controversy."