State of Minnesota v. Philip Morris Inc.
A state government and a health insurer brought an action against five tobacco companies and two trade associations under various theories of law, claiming that the defendants had suppressed information about the negative health effects of tobacco use and had manipulated the nicotine content of cigarettes to stimulate addiction. On appeal, the Court considered whether the health insurer possessed standing to bring the claims asserted by the plaintiffs. Because the insurer was not harmed directly by a breach of an assumed duty to protect public health, the Court found that the insurer lacked standing to bring tortious claims based on this duty. The Court further held that the insurer possessed standing to bring claims of consumer protection and antitrust violations pursuant to statutory language providing for redress of indirect harms. Finally, the Court held that the insurer possessed associational standing to pursue equitable claims requesting injunctive relief.