Izzarelli v. R.J. Reynolds Tobacco Co.

Summary

The court answered the certified question in the negative, holding that the good-tobacco exception does not categorically bar a strict products liability claim based on cigarette design choices that increase consumption and carcinogen exposure. It clarified that the modified consumer expectation test is the primary test for design-defect claims, while the ordinary consumer expectation test is limited to products that fail to meet commonly accepted minimum safety expectations. The court concluded that the plaintiff's claim properly proceeded under the modified test because it challenged specific design features rather than cigarettes generally.