The Eleventh Circuit recently affirmed dismissal of more than 700 lawsuits filed on behalf of Florida smokers and their families for a variety of procedural failures. 4432 Individual Tobacco Plaintiffs v. Various Tobacco Companies, Nos. 13-10839; 13-12901; 13-14302 (11th Cir. Sept. 10, 2014). The cases were part of claims filed on behalf of more than 4,000 putative plaintiffs after a related class action (Engle) was decertified.
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