In Castano v. American Tobacco Co., 84 F.3d 734 (5th Cir. 1996), the appellate court reversed the trial court's certification of a class action for a class complaint against tobacco companies for injury related to nicotine addiction. Id. at 737. The trial court certified a class consisting of all nicotine-dependent persons in the United States that purchased and smoked cigarettes manufactured by the defendants as well as their estates, spouses, children, relatives, and significant others since 1943. Id. In reversing the trial court's decision, the appellate court noted a number of errors, including the failure to meet the superiority requirement. Id. at 746. The appellate court commented that class action status for mass tort litigation was generally disfavored, in part because it could strengthen non-meritorious claims. Id. The court also noted that the district court certified the class despite recognizing the extensive manageability problems because it believed doing so would preserve judicial resources in the millions of inevitable individual trials. Id. at 747. It was in this context that the appellate court found that the lack of other lawsuits did not support the trial court's action in certifying the class. Id. The court found that, in the absence of other litigation and given that the claims were based on a new theory of liability, a potential judicial crisis was just speculation. Id. at 748. The court also found that the most "compelling rationale" for finding superiority in a class action was missing in that case--the existence of a negative value suit. Id. Individual suits were feasible given that potential damage claims were high, punitive damages were available in most states, and the prevailing party could recover attorneys' fees. Id.