## Facts

- Robert A. Wright, an Iowa resident, alleged smoking-related personal injuries after long-term cigarette use beginning in the 1950s; DeAnn K. Wright asserted derivative claims.
- The Wrights sued multiple cigarette manufacturers and related entities, alleging cigarettes were defectively designed and unreasonably dangerous, and that defendants misrepresented and concealed health and addiction risks.
- In the underlying federal action, the Wrights pleaded negligence, strict liability, breach of implied and express warranties, breach of assumed duty, fraudulent misrepresentation, fraudulent nondisclosure, and civil conspiracy.
- The manufacturers argued that smoking risks were common knowledge, negating design-defect and related theories, and disputed any duty to disclose beyond existing warnings.
- The U.S. District Court for the Northern District of Iowa certified unsettled questions of Iowa law to the Iowa Supreme Court; the Iowa Supreme Court addressed only those legal questions, not merits liability.

## Issues

1. What standard governs Iowa design-defect claims, including claims involving cigarettes, and what role do consumer expectations and “common knowledge” play?
2. Whether an Iowa civil-conspiracy claim must be predicated on an intentional tort.
3. When, if ever, a manufacturer’s nondisclosure or failure to warn can support common-law fraud.
4. Whether general advertisements and public statements can create a duty under Restatement (Second) of Torts § 323 (voluntary undertaking).
5. Whether a smoker can pursue manufacturing-defect, implied-warranty, or tort theories when the cigarettes consumed were in the condition intended by the manufacturer.

## Decision

- Iowa design-defect law follows Restatement (Third) of Torts: Products Liability §§ 1–2, emphasizing a risk-utility framework; consumer expectations are relevant but not dispositive.
- “Common knowledge” of smoking risks does not categorically bar design-defect claims; it is a factor within the defect analysis.
- Civil conspiracy in Iowa may be based on actionable wrongful conduct even if the underlying wrong is not an intentional tort.
- Nondisclosure supports a fraud claim only when disclosure is needed to prevent a prior affirmative representation from being misleading.
- Manufacturer advertising and generalized public statements do not constitute an “undertaking” creating a § 323 duty to protect smokers.
- No manufacturing-defect, warranty, or tort liability exists on a manufacturing-defect theory when the cigarettes smoked conformed to the manufacturer’s intended condition.

## Legal Principles

- Iowa design-defect claims are governed by Restatement (Third) §§ 1–2; “unreasonably dangerous” terminology from Restatement (Second) § 402A is not controlling for design-defect analysis.
- Risk-utility balancing is central to design-defect determinations; consumer expectations and consumer knowledge inform, but do not control, that inquiry.
- Civil conspiracy requires an agreement and actionable underlying wrongful conduct, but the underlying wrong need not be an intentional tort.
- Fraud by omission generally requires a misleading partial disclosure; absent such a prior representation (or comparable basis), there is no general fraud duty to disclose all material product-risk information.
- Voluntary-undertaking liability under Restatement (Second) § 323 requires an undertaking to render protective services; generalized advertising and public statements do not suffice.
- A manufacturing defect requires a departure from intended design; harm caused by intended product characteristics must be pursued, if at all, under design-defect or warning-based theories rather than manufacturing defect.

## Conclusion

Answering certified questions, the Iowa Supreme Court modernized Iowa design-defect doctrine by adopting Restatement (Third) §§ 1–2 and treating “common knowledge” as non-dispositive, broadened civil-conspiracy availability beyond intentional tort predicates, limited fraud-by-omission to misleading partial disclosures, rejected § 323 duties based on general advertising, and foreclosed manufacturing-defect and related theories where cigarettes conformed to the manufacturers’ intended condition.


Wright v. Brooke Grp. Ltd., 652 N.W.2d 159 (Iowa 2002)