Lucille Ruth Soffer, etc. v. R.J. Reynolds Tobacco Company

The issue framed by the certified question in this case is whether individual members of the Engle class are entitled to seek punitive damages under theories of negligence or strict liability in their individual lawsuits following this Court’s de-certification of the class action in Engle v. Liggett Group, Inc., 945 So.2d 1246, 1254 (Fla.2006). In Soffer v. R.J. Reynolds Tobacco Co., 106 So.3d 456, 460-61 (Fla. 1st DCA 2012), the First District Court of Appeal, in a split decision, held that individual members of the Engle class action are bound by the procedural posture of the Engle class…