Friday, December 6, 2013

Castano v. American Tobacco Co. case brief

Castano v. American Tobacco Co. case brief summary
84 F.3d 734 (1996)

Appellant tobacco companies sought review of an order of the United States District Court for the Eastern District of Louisiana, which certified appellee nicotine addiction plaintiffs as a class pursuant to Fed. R. Civ. P. 23(a) and 23(b)(3) for their class complaint against appellants. Specifically, the court certified the class on the issues of core liability and punitive damages.

Appellee nicotine addiction plaintiffs were certified as a class by the district court pursuant toFed. R. Civ. P. 23(a) and 23(b)(3) in their class complaint against appellant tobacco companies, which alleged that appellants fraudulently failed to inform consumers that nicotine is addictive and manipulated the level of nicotine in cigarettes to sustain their addictive nature.


  • The court reversed the certification and held that the district court erred in its class certification analysis and abused its discretion by failing to consider how variations in state law would affect predominance and superiority, and by not including consideration of how a trial on the merits would be conducted in its predominance inquiry. 
  • The court also held that appellees' class independently failed the superiority requirement of Fed. R. Civ. P. 23(b)(3), because the lack of individual trials based on appellees' novel theory made it impossible to properly conduct the predominance and superiority analyses required by the rule. 
  • The court noted that the amount of judicial resources that would be conserved in trying appellees' claims through the class action method was highly speculative.

The court reversed and remanded the district court's order certifying appellee nicotine addiction plaintiffs as a class, with instructions that the class complaint be dismissed. The court held that the district court abused its discretion by ignoring variations in state law and how a trial on appellees' alleged causes of action against appellant tobacco companies would be tried.

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