Castleman v. R.J. Reynolds Tobacco Co.
97 So. 3d 875
| Fla. Dist. Ct. App. | 2012Background
- The Castlemans sued RJ Reynolds for tobacco-related injuries; trial court granted summary judgment to Reynolds after finding they did not qualify for Engle class or extended filing period.
- Mr. Castleman smoked from 1953 to 1983, quit in 1983, then developed respiratory and chest symptoms in the 1990s; physicians attributed issues to smoking only in 1998.
- Engle v. Liggett Group, Inc. created a sanctioned class and extended limitations for certain Florida residents as of a 1996 cutoff date (Nov. 21, 1996).
- The mandate in Engle issued January 11, 2007, allowing class members to file by January 11, 2008; Castlemans filed on January 10, 2008.
- The dispositive issue is whether the Castlemans manifested tobacco-related illness by November 21, 1996 to qualify as Engle class members; if not, their suit is time-barred.
- Florida Supreme Court decisions on manifestation and limitations informed whether the Castlemans’ claims fell within Engle’s extended window.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Did Castlemans fit Engle class as of 1996? | Castleman family members fit the class description as of 1996. | They did not meet Engle’s manifestation requirement by 1996. | No; Castlemans did not manifest tobacco-related illness by 1996. |
| Was there a pre-1996 manifestation sufficient to trigger Engle rights? | Any manifestations indicating tobacco-related disease should qualify. | Manifestations must disclose a disease caused by tobacco and be present by 1996. | Manifestations did not disclose a tobacco-related disease before 1996. |
| Does failure to qualify for Engle class bar the action even with the 2008 deadline? | Engle class membership would render the 2008 deadline applicable. | If not Engle class member, action is time-barred regardless of the deadline. | Action barred; no Engle class membership. |
Key Cases Cited
- Engle v. Liggett Group, Inc., 945 So.2d 1246 (Fla. 2006) (established Engle class and extended filing protections)
- Frazier v. Philip Morris USA Inc., 89 So.3d 937 (Fla. 3d DCA 2012) (definition of manifestation in creeping-disease context)
- Carter v. Brown & Williamson Tobacco Corp., 778 So.2d 932 (Fla. 2000) (articulates manifestation concept for tobacco-related claims)
- Rearick v. R.J. Reynolds Tobacco Co., 68 So.3d 944 (Fla. 3d DCA 2011) (Engle class qualification governs timeliness of suit)