ELEANOR FARCHIONE v. R.J. REYNOLDS TOBACCO COMPANY & Another.

CourtMassachusetts Appeals Court
DecidedAugust 6, 2025
Docket24-P-0659
StatusUnpublished

This text of ELEANOR FARCHIONE v. R.J. REYNOLDS TOBACCO COMPANY & Another. (ELEANOR FARCHIONE v. R.J. REYNOLDS TOBACCO COMPANY & Another.) is published on Counsel Stack Legal Research, covering Massachusetts Appeals Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
ELEANOR FARCHIONE v. R.J. REYNOLDS TOBACCO COMPANY & Another., (Mass. Ct. App. 2025).

Opinion

NOTICE: Summary decisions issued by the Appeals Court pursuant to M.A.C. Rule 23.0, as appearing in 97 Mass. App. Ct. 1017 (2020) (formerly known as rule 1:28, as amended by 73 Mass. App. Ct. 1001 [2009]), are primarily directed to the parties and, therefore, may not fully address the facts of the case or the panel's decisional rationale. Moreover, such decisions are not circulated to the entire court and, therefore, represent only the views of the panel that decided the case. A summary decision pursuant to rule 23.0 or rule 1:28 issued after February 25, 2008, may be cited for its persuasive value but, because of the limitations noted above, not as binding precedent. See Chace v. Curran, 71 Mass. App. Ct. 258, 260 n.4 (2008).

COMMONWEALTH OF MASSACHUSETTS

APPEALS COURT

24-P-659

ELEANOR FARCHIONE1

vs.

R.J. REYNOLDS TOBACCO COMPANY & another.2

MEMORANDUM AND ORDER PURSUANT TO RULE 23.0

The plaintiff's decedent, Joseph Pritzky, began smoking

cigarettes in 1961 when he was ten years old and quit when he

was thirty-six years old. He was over sixty years old when he

was first diagnosed with lung cancer in 2014. Several years

later, he was diagnosed with another lung cancer, which led to

his death in 2023.

In this lawsuit the plaintiff claims that the wrongful

conduct of cigarette manufacturer R.J. Reynolds Tobacco Company3

1Individually and as special personal representative of the estate of Joseph Pritzky.

2 The Stop & Shop Company, LLC. 3R.J. Reynolds Tobacco Company is the corporate successor to Lorillard Tobacco Company and the Brown & Williamson Tobacco and the Stop & Shop Company, LLC, caused Pritzky's lung cancers

and ultimately his death.4 The complaint raises several counts

including, as relevant to this appeal, breach of implied

warranty against both defendants and negligence and civil

conspiracy against Reynolds only. These claims were tried to a

jury over twenty-two days, after which the jury returned a

verdict finding that (1) the defendants did not breach an

implied warranty by manufacturing cigarettes or by selling them

to Pritzky; (2) Reynolds was not negligent in marketing

cigarettes to Pritzky when he was a minor; (3) Reynolds was

negligent in distributing cigarettes to Pritzky and in failing

to warn him of the health risks of cigarettes when he was a

minor, but its negligence did not cause Pritzky's lung cancers;

and (4) Pritzky did not reasonably rely to his detriment on a

misrepresentation of material fact made further to a conspiracy

between Reynolds and other tobacco companies or organizations.

The plaintiff now appeals from the judgment entered for the

defendants on all claims, arguing that the judge made dozens of

evidentiary errors during the course of the trial. We conclude

Company. For convenience we will refer to the three companies interchangeably as "Reynolds."

4 The case was originally brought in 2017 by Pritzky on his own behalf. Following his death in 2023, the special personal representative of his estate filed an amended complaint substituting herself as the plaintiff.

2 that most of these arguments are waived and, as to the

remainder, that the plaintiff has failed to show either an abuse

of discretion or prejudice entitling her to a new trial.

Accordingly, we affirm.

1. Standard of review. We review the judge's evidentiary

rulings for an abuse of discretion. See N.E. Physical Therapy

Plus, Inc. v. Liberty Mut. Ins. Co., 466 Mass. 358, 363 (2013).

This standard requires the plaintiff to show that the judge made

a "clear error of judgment in weighing the factors relevant to

the decision . . . such that the decision falls outside the

range of reasonable alternatives" (quotation and citation

omitted). L.L. v. Commonwealth, 470 Mass. 169, 185 n.27 (2014).

In addition, to be entitled to a new trial, the plaintiff must

show that the errors, if any, adversely affected her substantial

rights. See DeJesus v. Yogel, 404 Mass. 44, 47-48 (1989).

"[T]he substantial rights of a party are adversely affected when

relevant evidence is erroneously excluded that, viewing the

record in a commonsense way, could have made a material

difference." Id. at 48.

2. Evidence related to negligent marketing claim. The

majority of the plaintiff's arguments concern the judge's

exclusion of evidence related to the negligent marketing claim.

The plaintiff puts this evidence into three categories:

3 internal company documents, advertising on television shows, and

portions of Pritzky's recorded deposition testimony. We will

address each in turn and then turn to the question of prejudice.

a. Internal company documents. The plaintiff begins this

part of her brief by listing seventeen documents that she claims

the judge erroneously excluded. She then fails, however, to

offer any argument regarding most of those documents. While she

claims generally that the judge erred by excluding "many"

documents "on the grounds that the terms used in the documents

. . . were not explicitly defined to mean 'under 18,'" she fails

to specify which of the documents in the list of seventeen fall

into this category.5 We need discuss only those challenges that

are individually addressed in the brief and deem the rest to be

waived. See Mass. R. A. P. 16 (a) (9) (A), as appearing in 481

Mass. 1628 (2019).

The plaintiff has also waived some challenges by failing to

adequately address the substance of the judge's rulings. The

judge excluded three documents -- a 1974 marketing plan, a 1974

5 The only record citations the plaintiff provides are to four pages of the record appendix, each containing four pages of the trial transcript. But she does not explain which pages and rulings correspond to which document, nor does she address the specific grounds the judge gave for her rulings, including that one document referred to people aged "25 to 44" and another related to sales of cigarettes in States where the legal age to purchase was sixteen.

4 document concerning Reynolds's domestic operating goals, and a

1980 interoffice memorandum -- on the ground that they were

"incomplete" because the plaintiff failed to submit an

attachment. The plaintiff relegates her discussion of this

ruling to a footnote and, even there, makes only a summary

assertion that the attachment was relevant to only one of the

three documents. Likewise, the plaintiff fails to grapple with

the judge's reasons for excluding two 1963 letters from Grey

Advertising to Reynolds and a 1966 letter from Reynolds to Grey

Advertising.6 These challenges are all waived. See Mass.

R. A. P. 16 (a) (9) (A); Boston Edison Co. v. Massachusetts

Water Resources Auth., 459 Mass. 724, 726 n.3 (2011) (deeming

argument raised only in footnote to be waived).

Next, the plaintiff has failed to show that the judge

abused her discretion in excluding a 1963 letter from an

advertising agency to Reynolds. Attached to the letter was a

photograph of "Little Ritchie," a child celebrity, being handed

a cigarette by an adult. The judge excluded the letter as

irrelevant, noting that the plaintiff offered nothing to show

"that the people handing [the child] a cigarette had anything to

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Related

DeJesus v. Yogel
533 N.E.2d 1318 (Massachusetts Supreme Judicial Court, 1989)
Commonwealth v. Durning
548 N.E.2d 1242 (Massachusetts Supreme Judicial Court, 1990)
L.L., a juvenile v. Commonwealth
20 N.E.3d 930 (Massachusetts Supreme Judicial Court, 2014)
Boston Edison Co. v. Massachusetts Water Resources Authority
947 N.E.2d 544 (Massachusetts Supreme Judicial Court, 2011)
N.E. Physical Therapy Plus, Inc. v. Liberty Mutual Insurance
995 N.E.2d 57 (Massachusetts Supreme Judicial Court, 2013)
Chace v. Curran
881 N.E.2d 792 (Massachusetts Appeals Court, 2008)

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ELEANOR FARCHIONE v. R.J. REYNOLDS TOBACCO COMPANY & Another., Counsel Stack Legal Research, https://law.counselstack.com/opinion/eleanor-farchione-v-rj-reynolds-tobacco-company-another-massappct-2025.