Waggoner v. R.J. Reynolds Tobacco Co.

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.

Waggoner v. R.J. Reynolds Tobacco Co., 835 F.Supp.2d 1244 (M.D. Fla., 2011).

  • United States
  • Dec 20, 2011
  • U.S. District Court, M.D. Florida

Parties

Plaintiff

  • Robert Waggoner
  • Victoria Waggoner

Defendant R.J. Reynolds Tobacco Co.

Legislation Cited

Full Faith and Credit Act, 28 USC section 1738

Related Documents

Type of Litigation

Tobacco Control Topics

Substantive Issues

Type of Tobacco Product

None

"This Court must determine whether Engle III, Martin, and Jimmie Lee Brown combine to deny Defendants their constitutional due process rights. Defendants had full notice and opportunity to be heard in the year-long trial of Phase I of the Engle case. Special jury findings that individually addressed each Defendant's conduct went against the Defendants. The Florida Supreme Court's decision in Engle III(as implemented by Martin and Jimmie Lee Brown) to give those Phase I findings "res judicata" effect for future cases was a constitutionally permissible application of Florida issue preclusion law in these sui generis cases. "We must bear in mind that no single model of procedural fairness, let alone a particular form of procedure, is dictated by the Due Process Clause. The very nature of due process negates any concept of inflexible procedures universally applicable to every imaginable situation." Kremer, 456 U.S. at 483, 102 S.Ct. 1883 (citations and quotations omitted). Defendants' due process rights are not being violated."