Mealey's (June 17, 2019, 11:51 AM EDT) -- ATLANTA — The 11th Circuit U.S. Court of Appeals should reverse a lower court’s denial of Philip Morris USA Inc.’s motion for judgment as a matter of law (JMOL) because the plaintiff’s evidence was insufficient to establish reliance and legal causation elements of fraud claims, the company says in an April 24 brief supporting its appeal in a Florida Engle progeny case that resulted in a $17 million judgment against it (Donna Brown v. Philip Morris USA Inc., No. 15-13160, M.D. Fla.)....