Florida's Fourth District Court of Appeal ruled Wednesday that a jury could have based its decision to award punitive damages on, or was influenced by, improperly admitted conspiracy claim evidence, leading to a $2 million punitive damages award being reversed for a decedent's estate.

The Fourth DCA held the Palm Beach Circuit Court erred in letting jurors consider evidence of the conspiracy in determining the entitlement to, and the amount of, punitive damages by the plaintiff, the estate of Lloyd Spurlock, against defendant R.J. Reynolds Tobacco Co. The appellate court found that the error had been committed despite the trial court ultimately ruling that the conspiracy did not cause the decedent's injury.