R.J. Reynolds Tobacco Co. v. Martin
2010 Fla. App. LEXIS 19008
| Fla. Dist. Ct. App. | 2010Background
- This is the first Engle progeny appeal to a Florida district court after Engle v. Liggett Group, Inc.
- Engle decertified the class but gave Phase I findings and related issues res judicata effect in later individual actions.
- Martin, as an Engle class member, sues RJR for Benny Martin's death with claims including strict liability, fraud by concealment, civil conspiracy, negligence, and punitive damages.
- The trial court instructed that Phase I findings bind the Engle class conduct elements and that Martin could rely on them in proving her claims.
- Jury found addiction and conspiracy to conceal as legal causes of Martin’s death, allocated 66% to RJR and 34% to another party, and awarded compensatory and punitive damages.
- The appellate court analyzes scope of Engle preclusion, causation, reliance, and the punitive damages award under Florida law and due process.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Preclusive effect of Engle Phase I findings | Martin can rely on Phase I findings to prove conduct elements. | Phase I findings are too broad and do not prove individual causation. | Phase I findings establish conduct elements and bind Martin's claims. |
| Causation and reliance proof | Independent evidence supports causation and detrimental reliance, beyond Engle findings. | Engle findings alone should determine causation; lack of direct reliance proof defeats some claims. | Martin proved legal causation and detrimental reliance and the evidence supports punitive liability. |
| Punitive damages amount and due process | The award reflects clear evidence of wanton conduct and should not be capped by remittitur; ratio is permissible. | Punitive award is excessive and violates due process given compensatory damages and company finances. | The $25 million punitive award is not excessive under due process and supports remittitur denial. |
Key Cases Cited
- Engle v. R.J. Reynolds Tobacco Co., 945 So.2d 1246 (Fla. 2006) (Engle decertified class but phase findings have res judicata effect in later trials)
- Brown v. R.J. Reynolds Tobacco Co., 611 F.3d 1324 (11th Cir. 2010) (Phase I findings can be used to establish elements if applicable)
- Owens-Corning Fiberglas Corp. v. Ballard, 749 So.2d 483 (Fla. 1999) (punitive award nearly 18x compensatory upheld under cap exception)
- Exxon Shipping Co. v. Baker, 554 U.S. 471 (U.S. 2008) (no bright-line ratio; maritime context; supports flexibility in ratios)
- State Farm Mut. Auto. Ins. Co. v. Campbell, 538 U.S. 408 (U.S. 2003) (limits on punitive damages with respect to ratio and due process)
- Cooper Indus., Inc. v. Leatherman Tool Group, 532 U.S. 424 (U.S. 2001) (due process framework for punitive damages)