United States

The widow of a smoker sued R.J. Reynolds Tobacco Company (RJR) for damages for her husband’s death. The jury found that addiction to RJR cigarettes was a legal cause of the husband’s death, as was RJR’s conspiracy to conceal information about the dangers of cigarettes, and awarded damages to the widow. This appeals court decision affirms the trial court’s decision, including that members of an earlier class action lawsuit (Engle v. Liggett Group, Inc.) may rely upon the findings from the class action in their individual lawsuits. In particular, the court ruled that individual Engle plaintiffs may rely on the jury findings in Engle to establish the asserted claims, in this case strict liability, fraudulent concealment, civil conspiracy, and negligence. The plaintiff need only prove causation, that they relied on the tobacco companies’ statements to their detriment, and that they incurred damages.