Mealey's (November 28, 2018, 12:20 PM EST) -- ATLANTA — In a Nov. 26 holding, the 11th Circuit U.S. Court of Appeals reversed a Florida federal judge’s grant of judgment as a matter of law (JMOL) on behalf of Philip Morris USA Inc. on a former smoker’s intentional tort claims and directed the trial court to reinstate a jury’s $20 million punitive damage award on her behalf (Bernard Cote v. Philip Morris USA Inc., Nos. 15-15633, 16-15957, 11th Cir., 2018 U.S. App. LEXIS 33138)....