## Facts

- Floyd F. Roysdon began smoking R.J. Reynolds “Camel” cigarettes in 1946 and later switched to “Winston.”
- Roysdon was unable to quit smoking and alleged addiction.
- In 1983, following surgery on his left foot, two incisions failed to heal due to severe peripheral atherosclerotic vascular disease, leading to a below-the-knee amputation.
- Medical testimony attributed Roysdon’s vascular disease to smoking.
- Floyd and Ruth Ann Roysdon sued Reynolds under Tennessee products-liability theories, alleging (1) failure to warn of vascular-disease risks and (2) cigarettes were defective and unreasonably dangerous.
- The case was removed to federal court on diversity jurisdiction.
- Tennessee’s statute of repose limited claimed harm to cigarettes smoked within the ten years before suit (approximately 1974–1984).

## Issues

1. Whether the Federal Cigarette Labeling and Advertising Act (FCLAA) preempted the state-law failure-to-warn claim based on cigarette health warnings.
2. Whether the evidence was sufficient under Tennessee products-liability law to allow a jury to find Reynolds’ cigarettes defective and unreasonably dangerous.

## Decision

- The Sixth Circuit affirmed dismissal of the failure-to-warn claim as preempted by the FCLAA.
- The Sixth Circuit affirmed a directed verdict for Reynolds on the “defective and unreasonably dangerous” claim.
- The court held the plaintiffs’ proof showed, at most, that smoking is dangerous and caused Roysdon’s injury, but did not create a jury question that Reynolds’ cigarettes were unreasonably dangerous under Tennessee law.

## Legal Principles

- The FCLAA preempts state-law claims that would impose additional or different cigarette health-warning duties than those required by federal law, including tort claims challenging warning adequacy.
- Under Tennessee products-liability law, liability requires proof that a product is defective or unreasonably dangerous.
- A product is not “unreasonably dangerous” when the alleged danger is within the ordinary consumer’s expectations.
- For cigarettes, generalized proof that smoking causes serious health risks is insufficient to establish that a particular manufacturer’s cigarettes are unreasonably dangerous absent evidence of dangers beyond ordinary consumer expectations or beyond cigarettes generally.

## Conclusion

The Sixth Circuit upheld federal preemption of state-law inadequate-warning claims about cigarette health risks and affirmed judgment for the manufacturer because the plaintiffs failed to present evidence that the defendant’s cigarettes were unreasonably dangerous under Tennessee’s consumer-expectation standard or materially more dangerous than cigarettes generally.


Roysdon v. R.J. Reynolds Tobacco Co., 849 F.2d 230 (6th Cir. 1988)