R.J. Reynolds prevails in Florida Supreme Court appeal involving interpretation of punitive damages statute
Client(s) R.J. Reynolds Tobacco Company
Jones Day successfully represented R.J. Reynolds Tobacco Company before the Florida Supreme Court in an Engle progeny appeal presenting an issue concerning interpretation of Florida's punitive damages statute. In its opinion in Sheffield v. R.J. Reynolds Tobacco Company, the Florida Supreme Court held that amendments to Florida's punitive-damages statute, which presumptively bar successive punitive-damages awards, apply to Engle progeny wrongful-death cases in which the smoker passed away after October 1, 1999.
In 1999, the Florida legislature amended the State's punitive-damages statute to presumptively bar successive punitive awards and more generally limit punitive damages. The Amendments provide that they apply to all causes of action that "arise" after October 1, 1999. The Sheffield appeal presented the Florida Supreme Court with the question whether the Amendments apply to an Engle progeny wrongful-death action where the smoker manifested a smoking-related injury before the October 1, 1999 effective date but passed away after that date. Florida's intermediate courts had split on the issue: Three intermediate courts had held that the Amendments did not apply in that scenario, but Jones Day persuaded the Fifth District Court of Appeal to hold to the contrary.
The Florida Supreme Court agreed with the Fifth District, holding that the Amendments apply in every wrongful-death action premised on a death occurring after the Amendments' 1999 effective date. The Supreme Court concluded that a wrongful-death action "arises" when the decedent passes away, consistent with precedent establishing that there can be no wrongful-death action without a death and that a wrongful-death action accrues on the date of death. Thus, the Amendments "apply in Engle progeny wrongful death actions in which the decedent died after the[ir] effective date" of October 1, 1999.
R.J. Reynolds Tobacco Co. v. Sheffield, No. 5D17-2521 (Fla. 5th DCA); Sheffield v. R.J. Reynolds Tobacco Co., No. SC19-601 (Fla.)
