Engle v. Liggett Group, Inc., 945 So. 2d 1246 (Fla. 2006) (Supreme Court of Florida).
Engle v. Liggett Group is the seminal Florida Supreme Court decision that reshaped tobacco litigation and mass-tort procedure in the state.
Can a statewide class action of Florida smokers be maintained to adjudicate common liability issues and punitive damages, and if not, what is the proper treatment of the Phase I jury findings and the accrual standard for individual claims going forward?
Under Florida Rule of Civil Procedure 1.220(b)(3), class certification requires that common questions predominate over individual ones and that a class action be superior to other methods for fair and efficient adjudication. Even when a class is unmanageable for individualized issues (e.g., specific causation, reliance, comparative fault, and damages), a court may try genuinely common liability issues on a class‑wide basis and give those findings res judicata (issue‑preclusive) effect in subsequent individual suits by class members. Punitive damages cannot be awarded on a class‑wide basis prior to individualized determinations of compensatory damages and comparative fault because such an award is premature, risks duplicative punishment, and offends due process and Florida punitive‑damages law. For latent disease product‑liability claims, accrual occurs upon the manifestation of the disease or injury, and statutes of limitations are tolled during the pendency of a properly certified class action.
The Florida Supreme Court affirmed in part and reversed in part. It decertified the class for purposes of individualized liability and damages (including punitive damages) and vacated the $145 billion punitive award as excessive and procedurally improper. However, it preserved the Phase I jury findings on common issues and held they would have res judicata effect in subsequent, timely filed individual suits by class members against the Engle defendants. The Court adopted a manifestation standard for accrual of claims and allowed a one‑year window from the issuance of the mandate for class members to file individual actions utilizing the preserved findings.
Engle is a cornerstone of mass‑tort procedure and products‑liability law in Florida. Substantively, it cemented key industry‑wide findings about cigarettes' addictiveness, defectiveness, and the tobacco companies' wrongful concealment—findings later applied in thousands of "Engle progeny" cases. Procedurally, it models how courts can salvage common‑issue determinations for preclusive use while decertifying unmanageable damages classes, and it clarifies that class‑wide punitive damages are improper absent individualized compensatory findings. For students, Engle illustrates predominance and superiority analysis, the strategic use of issue preclusion, the due process constraints on punitive damages, and accrual principles for latent disease claims.