Izzarelli v. R.J. Reynolds Tobacco Co.

Summary

The concurrence agrees with the majority’s negative answer to the certified question but rejects the majority’s continued use of Connecticut’s dual consumer-expectations standards for design-defect claims. It would adopt a risk-utility test requiring proof of a reasonable alternative design, subject to recognized exceptions, and would treat consumer expectations and obviousness as non dispositive factors. The concurrence therefore joins only the result, not the majority’s analysis.