Philip Morris USA, Inc. v. Douglas

The estate of a smoker filed a lawsuit against tobacco companies for her smoking-related death and the jury awarded her estate $2.5 million in damages. The Florida Supreme Court found that it was appropriate for the lower court to apply the findings from an earlier class action lawsuit (Engle v. Liggett Group, Inc.) to this case. In particular, the court found that plaintiffs do not have to reprove elements of their claim that were decided in the first phase of Engle, such as strict liability and negligence. The court ruled that applying these findings did not violate the tobacco companies’ due process rights because the companies had a full opportunity to dispute the class claims in the year-long Engle trial and because injured smokers must still prove their individual case against each tobacco company. Specifically, the court found that each plaintiff must establish (1) membership in the Engle class (i.e., they were addicted to cigarettes); (2) that addiction to smoking was a legal cause of their injuries; and (3) damages.


Philip Morris United States, Inc. v. Douglas, 110 So.3d 419 (Fla., 2013).

  • United States
  • Mar 14, 2013
  • Supreme Court of Florida


Plaintiff James L. Douglas


  • Liggett Group LLC
  • Philip Morris, USA
  • R.J. Reynolds Tobacco Company

Legislation Cited

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Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product