Walker Ex Rel. Estate of Walker v. R.J. Reynolds Tobacco Co., 734 F.3d 1278

Background

In the 1994 Engle class action (Brown/Engle), Florida plaintiffs tried a three‑phase class plan against major tobacco companies; Phase I tried common liability issues and returned broad findings that cigarettes cause disease, are addictive, and that each defendant engaged in various wrongful conduct.
The Florida Supreme Court approved some Phase I findings, decertified the class for Phase III, and held the approved Phase I findings would have res judicata effect in later individual suits (Engle v. Liggett Group, Inc.).
Lower courts disagreed over the preclusive scope: the Eleventh Circuit in Brown required showing the Phase I jury actually decided a defendant acted wrongfully as to the particular brand a plaintiff smoked; several Florida appellate courts later held the approved Phase I findings establish conduct elements for all class members.
The district court in Waggoner applied Florida appellate rulings and held that giving preclusive effect to the approved Phase I findings does not violate defendants’ federal due process rights; later the Florida Supreme Court in Douglas confirmed that the approved Phase I findings establish the conduct elements for individual Engle plaintiffs and that claim preclusion (res judicata) applies.
R.J. Reynolds challenged application of those preclusive findings in individual wrongful‑death suits (Walker and Duke), arguing the Phase I verdict was too ambiguous to satisfy due process; juries in the individual suits were instructed that conduct was conclusively established and awarded modest damages to plaintiffs.
The Eleventh Circuit affirmed, holding federal courts must give full faith and credit to the Florida Supreme Court’s interpretation so long as it meets minimum due process requirements; the court found no arbitrary deprivation of property and that R.J. Reynolds had a full and fair opportunity to litigate common liability.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Preclusive effect of Engle Phase I findings	Phase I findings establish defendants’ conduct elements for all class members; plaintiffs may rely on them in individual suits	Phase I verdict too general; plaintiffs must prove Phase I actually decided defendant acted wrongfully as to the specific brand/plaintiff	Florida Supreme Court (Douglas) and Eleventh Circuit: approved Phase I findings have res judicata effect as interpreted by Florida law; federal courts must follow that interpretation under §1738 if it satisfies due process
Due process challenge to state preclusion rule	N/A (plaintiffs seek preclusion)	Applying Phase I findings to later suits violates federal due process because jury did not make brand‑specific / actually‑decided findings	Eleventh Circuit: No due process violation; state rule was not arbitrary and defendants had full and fair opportunity to litigate common liability
Issue preclusion vs. claim preclusion (Fayerweather argument)	N/A	Defendants argued they have a constitutional right to issue preclusion (i.e., 'actually decided' requirement) rather than claim preclusion	Florida Supreme Court: Engle applied claim‑preclusion (res judicata); Eleventh Circuit: federal due process does not require adoption of federal common‑law issue‑preclusion form here
Whether Phase I jury actually decided brand‑specific conduct	Plaintiffs: jury decided common conduct applicable to all brands/class members	Defendants: ambiguity in verdict prevents concluding Phase I decided conduct as to particular brands/plaintiffs	Eleventh Circuit: Florida Supreme Court permissibly looked beyond the verdict to the record and trial plan to conclude the jury decided common liability issues; not arbitrary under due process

Key Cases Cited

Engle v. Liggett Group, Inc., 945 So. 2d 1246 (Fla. 2006) (Florida Supreme Court decertified class for Phase III and held certain Phase I findings would have res judicata effect)
Brown v. R.J. Reynolds Tobacco Co., 611 F.3d 1324 (11th Cir. 2010) (initial Eleventh Circuit interpretation requiring proof that Phase I actually decided defendant‑specific issues)
Philip Morris USA, Inc. v. Douglas, 110 So. 3d 419 (Fla. 2013) (Florida Supreme Court held approved Phase I findings establish conduct elements for all class members and applied res judicata)
Fayerweather v. Ritch, 195 U.S. 276 (1904) (discussed concerning limits of giving preclusive effect to issues not actually decided)
Marrese v. American Academy of Orthopaedic Surgeons, 470 U.S. 373 (1985) (Full Faith and Credit Act subject to Due Process constraints)
Kremer v. Chemical Construction Corp., 456 U.S. 461 (1982) (minimum procedural requirements of due process for preclusion principles)
Richards v. Jefferson County, Ala., 517 U.S. 793 (1996) (extreme applications of res judicata may conflict with federal rights)
Cipollone v. Liggett Group, Inc., 505 U.S. 504 (1992) (historical context on tobacco litigation cited by the court)