The 1890s' no-smoking movement faced the same directional issue as we do now. 2 Tobacco seller William B. Austin violated this law, was arrested, and was convicted. He appealed to the Tennessee Supreme Court. Their use is always harmful, never beneficial. 3 Austin appealed to the US Supreme Court, and lost again.
All cigarettes contain deleterious ingredients.
All cigarettes emit ingredients deleterious to health. It needs enforcing . It is unlawful to do so even if death is slow. A Report of the Surgeon General . Michigan Statute Annotated 28.216 .