Walker v. R.J. Reynolds Tobacco Company

An appeals court upheld judgments in favor of two smokers who sued R.J. Reynolds Tobacco Company (RJR) for injuries caused by smoking. The court found that RJR had not been deprived of its right to due process when two juries awarded money damages to the survivors of two smokers. The appeals court found that RJR had a full and fair opportunity to be heard in an earlier class action lawsuit against major tobacco companies (Engle v. Liggett Group, Inc.) and that it was permissible to apply the findings from this class-action regarding tobacco companies’ liability in later lawsuits. Therefore, the court ruled that individuals in later lawsuits need only prove causation and damages specific to their case. They do not have to retry the issue of whether tobacco companies are liable on issues such as misrepresenting the health effects of smoking and producing a defective product.

Walker v. R.J. Reynolds Tobacc Co., 734 F.3d 1278 (11th Cir. 2013).

  • United States
  • Oct 31, 2013
  • U.S. Court of Appeals, Eleventh Circuit

Parties

Plaintiff

  • Alvin Walker, as Personal Representative of the Estate of Albert Walker
  • George Duke, III, as Personal Representative of the Estate of Sarah Duke

Defendant R.J. Reynolds Tobacco Company, individually and as successor by merger to the Brown & Williamson Tobacco Corporation and the American Tobacco Company

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

"Our deference to the decision in Douglas does not violate the constitutional right of R.J. Reynolds to due process of law. Whether the Supreme Court of Florida calls the relevant doctrine issue preclusion, claim preclusion, or something else, is no concern of ours. We must give full faith and credit to the decision of the Supreme Court of Florida about how to resolve this latest chapter of the intractable problem of tobacco litigation...So juries often either discounted or rejected the claims of smokers who sought to hold tobacco companies liable for the well-known harms to their health caused by smoking. But a ―wave of suits, brought by resourceful attorneys representing vast claimant pools... We cannot say that the procedures, however novel, adopted by the Supreme Court of Florida to manage thousands of these suits under Florida law violated the federal right of R.J. Reynolds to due process of law."