New Jersey Carpenters Health Fund v. Philip Morris, Inc.

Brief Fact Summary.

New Jersey Carpenters Health Fund filed suit against Philip Morris, Inc.for fraudulent misrepresentation.

Synopsis of Rule of Law.

A plaintiff’s injuries have to be closely related to a falsification in order to sustain a claim for fraudulent misrepresentation.

Facts.

New Jersey Carpenters Health Fund (NJ) filed suit against Philip Morris, Inc. (Philip) for fraudulent misrepresentation claiming that Philip withheld information about the risks associated with smoking. NJ claimed that Philip directed the falsification to them to increase the plaintiff’s healthcare costs associated with the risks of smoking. Philip filed a motion to dismiss for failure to state a claim.

Issue.

Whether a plaintiff’s injuries have to be closely related to a falsification in order to sustain a claim for fraudulent misrepresentation?

Held.

Yes. The defendant’s motion to dismiss is denied. The defendants knowingly withheld the risks associated with smoking, causing the plaintiffs to suffer the increased healthcare costs associated with smoking.

Discussion.

Known as remote cause, a plaintiff’s injuries have to be closely related to a falsification in order to sustain a claim for fraudulent misrepresentation.A defendant is guilty of fraudulent misrepresentation if the plaintiff can prove that the defendant made a false representation regarding a material fact, the defendant knew that the statement was false, made the statement in order to deceive the plaintiff, and the plaintiff relied on the false representation.