Law360, New York (May 19, 2016, 11:54 AM EDT) -- The Connecticut Supreme Court recently altered the legal landscape in Connecticut for design defect product liability claims. The case, Izzarelli v. R.J. Reynolds Tobacco Co.,[1] nicknamed by the media as the "Good Tobacco" litigation, has received attention for its holding that strict liability lawsuits against cigarette manufacturers in Connecticut are not precluded by a 1965 comment to the Restatement (Second) of Torts. That comment states that "good tobacco" is not defective just because the effects of smoking are harmful. This holding, while important in its own right, may have less general impact than the Izzarelli court's modification and clarification of the standards for a product liability claim based on a defective design in Connecticut. In Izzarelli, the court reevaluated the design defect standards for the first time in almost 20 years and established that the primary and default test to be used in design defect claims is now a modified consumer expectations standard, not the ordinary consumer expectations standard, regardless of the complexity of the underlying product. Connecticut's modified consumer expectations test requires a multifactor balancing of the risks and utilities of a product to determine whether a fully informed consumer would consider the product unreasonably dangerous. Approximately 15 states use a standard in design defect cases that does not exactly follow either the consumer expectations test or the Restatement (Third) approach....