American Tobacco Co. v. Grinnell

Brief Fact Summary.

Plaintiff’s family sued Defendant for death of Plaintiff, stating that Defendant failed to warn Plaintiff of the risks associated with the use of Defendant’s cigarettes. The trial court awarded summary judgment to Defendant. The Court of Appeals reversed. Defendant appealed.

Synopsis of Rule of Law.

If a manufacturer knows or should have known that its product could potentially cause harm to a user, the manufacturer has a duty to warn the user, unless the risks are common knowledge.

Facts.

American Tobacco Co. (Defendant) manufactured cigarettes. Grinnell (Plaintiff) smoked Defendant’s cigarettes from 1952 until 1985, when he was diagnosed with lung cancer. Plaintiff died soon after initiating a suit against Defendant. Plaintiff’s family continued the action, claiming that Defendant knew or should have known the dangers of smoking, including addictiveness, actively hid these dangers, and failed to warn Grinnell.

Issue.

Whether a manufacturer has a duty to warn about the risks of its product if the risks are common knowledge.

Held.

No. A manufacturer only has the duty to warn if the risks are not common knowledge. The Court of Appeals’ decision was affirmed in part and reversed in part.

Dissent.

(Hecht, J.): The district court’s grant of summary judgment should be affirmed on all claims. Smokers inherently know about smoking’s addictive qualities because they all know that it is difficult to quit smoking. Moreover, smokers do not die from the addiction to smoking. Furthermore, if the court were to find that addictiveness alone made cigarettes defective, Grinnell’s award should be limited to the damages caused by addictiveness.

Discussion.

In order for the risks to be common knowledge, they must be “so well known to the community as to be beyond dispute.†The Court determined that when Grinnell started smoking, generally, the harms of smoking were common knowledge. However, the addictive nature was not. The Court found that even though the addictive quality was known when Grinnell started smoking, it was not common knowledge. Therefore, American breached their duty to warn Grinnell.