Huddleston v. R.J. Reynolds Tobacco Co.
(Wrongful Death US Dist. Ct. N GA 1998 Def. Verdict) Citation: 66 F.Supp.2d 1370 (16 Sep 1999)This wrongful death suit was brought by James Huddleston, as representative and executor of the estate of Elizabeth Irene Huddleston against R.J. Reynolds.
The plaintiff alleged that his wife smoked the defendant's cigarettes from 1939 until her death on March 30, 1998. She died of oat cell carcinoma caused by her exposure and addiction to cigarettes the defendant knew to be dangerous. The plaintiff alleged that the defendant conspired with other cigarette companies to conceal and mislead the public and scientific communities as to the risk inherent in smoking and addictive qualities of nicotine. The plaintiff claimed fraud, intentional exposure to hazardous substance, and violation of the state Racketeer Influenced and Corrupt Organization Act (RICO). The plaintiff sought compensatory and punitive damages.
The case was heard in the United States District Court for the Northern District of Georgia, Atlanta Division (Case No. 1:98-CV 1865 (TWT)), before the Honorable Judge Thrash. The judge (66 F.Supp.2d 1370) granted summary judgment to the defendant on September 16, 1999. He ruled that the plaintiff could not recover on his RICO claim because he failed to show the causal connection between the defendant's misrepresentations and his wife's death. The fraud claim failed without evidence that the deceased relied on the defendant's misrepresentations regarding the risks of cigarettes. The RICO and fraud claims were also preempted by the Federal Cigarette Labeling and Advertising Act because they were based on statements and advertisements made by the defendant. Any claims based on a general duty not to deceive were too fully intertwined with those that were preempted to be treated differently. State law did not recognize a claim for intentional exposure to hazardous substances in legal, non-defective products intended for consumer use.