In Nolan v. Weil-McLain, the Illinois Supreme Court substantially limited the so-called Lipke rule. For years, Illinois courts have relied on Lipke v. Celotex Corp. to prohibit an asbestos defendant from admitting evidence of a plaintiff's exposure to asbestos other than plaintiff's evidence regarding that defendant's alleged product or premise. In fact, even if an asbestos defendant claimed that the other exposures to asbestos were the sole proximate cause of the plaintiff's injury, Illinois courts still deemed the alternative exposure evidence inadmissible.
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