Mealey's (August 26, 2019, 10:41 AM EDT) -- NEW YORK — The Second Circuit U.S. Court of Appeals on Aug. 22 found that a district court misapplied the nonmutual offensive collateral estoppel standard in a lawsuit against a tobacco company that ended in a defense verdict but ruled that the court’s error does not require vacating the judgment and remanded the case for the lower court to consider whether the application of that standard would be unfair (Vincent J. Bifolck v. Philip Morris USA Inc., No. 17‐3927, 2nd Cir., 2019 U.S. App. LEXIS 25023)....