R.J. Reynolds Tobacco Co. v. (Jimmie Lee) Brown
The widow of a smoker sued R.J. Reynolds Tobacco Company (RJR) seeking damages for her husband’s death. The appeals court upheld a jury verdict finding RJR 50% responsible for the smoker’s death. The appeals court found that the trial court properly applied the findings from the earlier class-action lawsuit (Engle v. Liggett Group, Inc.), which determined that RJR was negligent by failing to exercise reasonable care in the manufacture of its cigarettes and that it was strictly liable by selling defective and unreasonably dangerous cigarettes. Therefore, the appeals court ruled that the widow in this case was only required to prove the remaining elements of legal causation and damages. Because the jury was asked to decide each of those questions individually (e.g., that the plaintiff was addicted to RJR cigarettes, that this addiction caused his death, that the unreasonably dangerous cigarettes caused his death, and that RJR’s negligence was a legal cause of his death), the appeals court found that the trial court properly applied the findings from the class-action decision in Engle.