Though cigarettes make a relatively small contribution to overall levels, they do man increased exposure for the individual smoker.
This was the first time that a New York court had held a tobacco company liable for an individual smoker's death.
Court decisions in cases brought by individual smokers have been mixed recently.
Those settlements did not foreclose the ability of individual smokers to pursue cases.
But it continues to face lawsuits from others, like individual smokers and trade unions.
It would not change the standard of proof required when individual smokers or their families sue tobacco companies for damages.
But that settlement did not foreclose claims by individual smokers, as in Florida.
With a growing number of options available, doctors are now able to create personalized treatment plans tailored to an individual smoker's needs and preferences.
Under his order, individual smokers and their survivors could still sue for compensation for lost income or health care costs.
The settlements did not bar class-action lawsuits or claims by individual smokers.