Walker v. R.J. Reynolds Tobacco Co.

Alvin Walker and George Duke (plaintiffs) sued R.J. Reynolds Tobacco Co. (R.J. Reynolds) for the deaths of their parents due to smoking-related illnesses. Prior to the Walker and Duke cases, R.J. Reynolds and other cigarette manufacturers were defendants in a class-action lawsuit filed by smokers and survivors in Florida state court. In that case, Engle v. Liggett Group, Inc., , common issues regarding the defendants’ conduct and the damaging effects of smoking were tried in front of a jury, which found that the tobacco companies, including R.J. Reynolds, manufactured cigarettes, concealed material information, breached a duty of care, and that smoking causes diseases and cancer. The tobacco companies appealed, but the Florida Supreme Court affirmed the jury’s verdict and indicated that the jury’s core findings regarding tortious-conduct would have res judicata effect for future tobacco litigation in Florida. The Florida Supreme Court further found in Philip Morris USA, Inc. v. Douglas, that the Engle jury’s findings were specific enough to establish relevant elements of claims brought by future Engle class-plaintiffs and that the preclusive effect of those findings did not violate R.J. Reynolds’s due-process rights because the findings were made after R.J. Reynolds had ample opportunity to argue and appeal its case. Walker’s and Duke’s cases were tried, and the jury entered verdicts partially in favor of Walker and Duke after being instructed that R.J. Reynolds marketed defective and dangerous cigarettes and was negligent, per the findings in Engle. R.J. Reynolds appealed on the grounds that its due-process rights were violated by the application of res judicata to the Walker and Duke lawsuits because the Engle jury did not make sufficiently specific findings.