In an October 31, 2013, opinion, Walker v. R.J. Reynolds Tobacco Company, the US Court of Appeals for the Eleventh Circuit held that a Florida class action against major tobacco companies was entitled to full faith and credit because the defendant's due process rights were not violated.

In 1994, a group of smokers and their survivors filed a class action in Florida state court in Engle v. Liggett Group, Inc. against major manufacturers of cigarettes in the US. The court in Engle certified the class. During the first phase of the class action, the jury decided that the tobacco companies breached a duty of care, manufactured defective cigarettes and concealed material information. However, the jury did not decide whether the tobacco companies were liable for damages to individual class members.

On interlocutory appeal, the Supreme Court of Florida decertified the class but held that these and certain other findings by the Engle jury must be given res judicata effect in subsequent individual litigation by class members against the defendants. Members of the Engle class proceeded to file thousands of individual cases in both federal and state courts.

The Supreme Court of Florida later held in Philip Morris USA, Inc. v. Douglas that the jury's findings in Engle have res judicata effect for common issues decided against the tobacco companies and that the only unresolved issues in the individual lawsuits filed afterward were specific causation and damages. The court in Douglas also held that giving preclusive effect to the Phase I findings did not violate the tobacco companies' due process.

In the present action, R.J. Reynolds appealed jury verdicts in favor of two plaintiffs. In both cases, the district court instructed the jury that Phase I conclusively established the tortious-conduct elements of the plaintiffs' claims. The only issues the juries were left to resolve were whether the decedents were members of the Engle class, causation and damages. R.J. Reynolds argued that applying res judicata in these later individual suits violated its due process right because the jury verdict in the Engle class action was too ambiguous to tell whether the jury found that each tobacco company acted wrongfully with respect to any specific brand of cigarette or any individual plaintiff.

In sua sponte vacating and reconsidering its earlier opinion, the Eleventh Circuit affirmed the two jury verdicts and gave full faith and credit to the decision in Engle. The Eleventh Circuit reasoned that giving preclusive effect to the findings from Phase I did not violate R.J. Reynolds' constitutional due process right because: