Philip Morris USA Inc. v. Douglas
Annotate this CasePlaintiff, the personal representative of the estate of Charlotte Douglas, filed a complaint against cigarette companies and industry organizations for damages on claims based on Charlotte's smoking-related death. After a jury trial, Plaintiff was awarded $2.5 million in damages. At issue on appeal was whether the trial court erred in the application of the Phase I findings in the class action case Engle v. Liggett Group, Inc. Charlotte was a member of the Engle class. The court of appeal affirmed, concluding that Plaintiff did not prove legal causation on his negligence theory but did prove legal causation on his strict liability claim. Although the court of appeal rejected Defendants' argument that applying res judicata to the findings violated their due process rights, it certified the due process question to the Supreme Court. The Court approved of the court of appeal's decision affirming the general verdict for Plaintiff based on strict liability but disapproved the court's rejection of negligence as a basis for the general verdict because the court's analysis required causation instructions and findings beyond those required by Engle. In addition, the Court answered that accepting as res judicata the eight Phase I findings approved in Engle did not violate Defendants' due process rights.
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