United States

A class of smokers in California filed an action against tobacco companies under California's Unfair Competition Law (UCL), alleging that the companies' manipulated and concealed the content and addictiveness of nicotine in their products and deceived the public by disseminating misleading advertisements about the negative health effects of smoking.  The defendants moved to decertify the class, arguing that the class members had failed to demonstrate injuries in fact to each member's personal property or money, as required for standing under the UCL.  The Court held: (1) that class standing under the UCL required only named class members, not absent class members, to demonstrate injuries in fact; and (2) that satisfaction of the UCL's causation element required evidence of actual reliance on the campaign of misleading advertisements and statements, though reliance on particular advertisements or statements did not need to be pled nor proven to "an unrealistic degree of specificity."