United States

This case arises out of a 1994 class action lawsuit brought by Florida smokers against major tobacco companies for damages caused by smoking (Engle v. Liggett Group, Inc.). In this case, the court found that applying the first phase of findings from the Engle case to future lawsuits by former class members does not violate tobacco companies’ due process rights. The court found that the tobacco companies had full notice and opportunity to be heard in the year-long trial in the Engle case. In applying the Engle findings to future cases, the court ruled that the jury should be asked to determine (1) whether the plaintiff is a member of the class (i.e., they were addicted to the company’s cigarettes, which caused their injuries); (2) whether the tobacco companies’ conduct was a legal cause of the plaintiff’s injury for each claim asserted (e.g., strict liability, negligence); and (3) whether the plaintiff was partially at fault.