Philip Morris USA Inc., et al. v. Richard Boatright, et ux.

The Florida Supreme Court has devised a new, class-action-specific doctrine of claim preclusion in order to facilitate the classwide adjudication of inherently individualized claims. Under this unprecedented approach to preclusion, the members of an issues class can rely on the class jury’s findings to establish elements of their claims in individual suits against the class-action defendants without having to show that the class jury actually decided those issues in their favor. For preclusion to apply, it is sufficient that the class jury might have decided those issues. According to the Florida Supreme Court, this unorthodox approach to the preclusive effect of class-action findings is consistent with due process because the defendants had an “opportunity to be heard” in the class proceedings. The question presented is whether the Due Process Clause is violated by a rule that permits plaintiffs to invoke a prior jury’s findings to establish elements of their claims without showing that those elements were actually decided in their favor in the prior proceeding, based merely on the fact that the defendant had an opportunity to be heard on those issues in the prior proceeding and the possibility that the relevant issues might have been decided in the plaintiffs’ favor in that proceeding.