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The court also rejected the plaintiffs claim that employers must offer more than one opportunity per year to satisfy the alternative standard and earn the full reward. However, the court refused to dismiss the plaintiffs claim regarding the alleged failure of the smoking cessation program to adequately disclose that participants can, in some circumstances, involve their personal physician in setting a participants RAS

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That period coincided with the last increase in the Illinois tax on cigarettes

However, by the late 1970s, television smoking ads had been banned and antismoking campaigns and nonsmokers' rights groups became more prevalent, likely contributing to a decline in smoking