Law360, New York (August 31, 2012, 6:43 PM ET) -- A Florida appeals court on Friday reversed part of a ruling in favor of R.J. Reynolds Tobacco Co. and Philip Morris USA Inc. in an Engle progeny case, finding that a smoker is not necessarily excluded from a class because he died outside of Florida.
A lower court granted summary judgment to the companies in a suit brought by Annie Bishop, the personal representative of Robert Ramsey, who allegedly died from smoking-related health issues in June 1992. It found that because Ramsey died when he was...