Joan Schoeff v. R.J. Reynolds Tobacco Company

Summary

The court held that Florida's comparative-fault statute does not reduce compensatory damages in an Engle progeny case when the jury finds for the plaintiff on intentional-tort claims, because the statutory intentional-tort exception applies to the case and the damages cannot be allocated between overlapping theories. The court also held that the plaintiff did not waive that exception and that the punitive award was neither unconstitutionally excessive nor subject to remittitur. The court quashed the district court's decision and approved the contrary result concerning compensatory damages.