Sheffield v. R.J. Reynolds Tobacco Company
Resolving a certified conflict among four DCAs, the Florida Supreme Court held that the 1999 amendments to section 768.73 capping/presumptively barring successive punitive damages awards apply to Engle progeny wrongful death actions where the smoker died after October 1, 1999. The Court reasoned that a wrongful death action is a new and independent statutory cause of action that arises (i.e., accrues) only upon death, so the causes of action here arose in 2007 and are governed by the amended statute. It approved the Fifth District's decision in Sheffield and disapproved Allen, Evers, and Konzelman.
Key facts
- Sheffield and other smokers' estates brought wrongful death actions against R.J. Reynolds Tobacco Company as Engle progeny cases, seeking punitive damages for deaths occurring after October 1, 1999.
- The trial court and four District Courts of Appeal reached conflicting decisions on whether the 1999 amendments to section 768.73—which cap and presumptively bar successive punitive damages awards for the same conduct—applied to these wrongful death actions.
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Why it matters
This decision definitively resolves a four-district conflict and gives tobacco and other repeat-defendant litigants a potent defense: prior punitive awards for the same course of conduct presumptively bar new punitive… — full analysis with a trial
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