Curtis v. Altria Group, Inc.
2012 Minn. LEXIS 211
| Minn. | 2012Background
- Marlboro Lights carried the label “lights” and the phrase “lowered tar and nicotine” on Minnesota cigarette packages from 1971 to the suit filing.
- In 1994, the Minnesota Attorney General sued Philip Morris and others under Minnesota consumer protection and related laws.
- The parties settled in 1998 via a Settlement Agreement that imposed marketing restrictions and required PM to pay over $100 million to the State annually; the State discharged Philip Morris from claims in exchange.
- In 2001, Curtis, on behalf of themselves and others, sued Philip Morris and Altria for similar misrepresentations under Minn. Stat. § 8.31, subd. 3a (private subdivision 3a claims).
- The district court granted PM partial summary judgment, holding that subdivision 3a claims were released by the Settlement Agreement and that they had no public-benefit under Ly v. Nystrom; the court of appeals reversed on the release issue.
- The Minnesota Supreme Court reversed, concluding the Settlement Agreement expressly released the private subdivision 3a claims as past and future conduct related to tobacco use, binding the respondents.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Authority to release subdivision 3a claims | Curtis argues the State AG cannot release private 3a claims. | Philip Morris contends the State’s settlement releases those claims. | State AG authority to release exists; private 3a rights are limited by public-benefit rule, but release here binds private plaintiffs. |
| Public-benefit requirement for private 3a claims | Ly public-benefit requirement should apply to private 3a claims. | PM argues public benefit not satisfied or bindingly released. | Ly’s public-benefit requirement remains applicable to private 3a claims. |
| Effect of the Settlement Agreement’s “future conduct” clause | Respondents were not bound by the settlement’s release of their claims. | Settlement’s “future conduct” release covers monetary claims tied to tobacco use. | Settlement Release expressly covers past and future monetary claims related to tobacco use, releasing Curtis’s 3a claims. |
Key Cases Cited
- Ly v. Nystrom, 615 N.W.2d 302 (Minn. 2000) (private 3a claims require public benefit; private rights limited by AG authority)
- Head v. Special Sch. Dist. No. 1, 288 Minn. 496, 182 N.W.2d 887 (Minn. 1970) (AG authority; public rights guidance in enforcement actions)
- Collins v. Minn. Sch. of Bus., Inc., 655 N.W.2d 320 (Minn. 2003) (private action under 3a may require public benefit; attorney fees rules noted)
- Dykes v. Sukup Mfg. Co., 781 N.W.2d 578 (Minn. 2010) (settlement contract interpretation; release of claims evaluated case-by-case)
- Pac. Indem. Co. v. Thompson-Yaeger, Inc., 260 N.W.2d 548 (Minn. 1977) (contractual release and scope of releases governed by intent and language)