In Nowicki v. Cessna the Fourth District Court of Appeals acknowledged that there is an exception to the eighteen-year statute of repose in federal General Aviation Revitalization Act of 1994 actions when fraud is involved. This case dealt with an airplane crash and wrongful death claim. In Williams v. State of Florida, decided September 21, 2011, the Fourth District held that there was evidence sufficient to support a finding that the murder was premeditated, despite that the Defendant husband's defense o "heat of the moment". The Defendant husband admitted that he had prayed before killing his wife and this indicated that he had a fully conscience purpose to kill her and enough time to reflect on the nature of the act and was direct evidence of premeditation, as was his statement threatening to kill his wife to his former girlfriend a month before the murder. In R.J Reynolds Tobacco Company v. Brown the Fourth District of the Supreme Court of Florida's decision in Engle v. Ligget Group, Inc. applied to an individual's case. The Engle case established the conduct and elements of strict liability and negligence claims. However, the remaining elements oflegal causation and damage still must be proven. The Fourth District also held that there was no error in a jury finding that the Defendant's negligence was a legal cause of death and that the smoker himself was 50% at fault. See R.J. Reynolds Tobacco Company v. Brown, 36 Fla. L. Weekly D2094, September 21, 2011.