News & Analysis as of

Causation Summary Judgment Toxic Exposure

Faegre Drinker Biddle & Reath LLP

Foundation, Not Façade — The Fifth Circuit Affirms the Proper Basis Requirement for Admissibility of Expert Opinions in Newsome v....

In a toxic tort case, plaintiffs must establish general causation. If a substance is incapable of causing the type of injury plaintiff claims, then it certainly didn’t cause theirs. Under Texas law, toxic tort plaintiffs must...more

Faegre Drinker Biddle & Reath LLP

Fifth Circuit Asks the Right Questions, Affirms Summary Judgment on Plaintiffs’ Herbicide Claims as Untimely and Lacking...

As Nobel laureate Richard Feynman once observed, “[w]isdom is knowing when to ask the right questions.” A related proposition is that wise jurists know how to identify and focus on the right questions. Motion practice can...more

Goldberg Segalla

Talc Defendant Unsuccessful on Summary Judgment

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Jurisdiction:  Supreme Court of New York, New York County - Plaintiff Lita Goldstein was diagnosed in March 2022 with mesothelioma. She initiated a suit against several defendants in May 2022, including Kolmar Laboratories...more

Goldberg Segalla

Talc Defendant Denied Summary Judgment in NYCAL

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Court: Supreme Court of New York, New York County - In this talc action, plaintiff Christina Thomas alleged she was exposed to asbestos from products manufactured by defendant Port Jervis Laboratories Inc., s/h/a Kolmar...more

Goldberg Segalla

Floor Tile Manufacturer’s Motion for Renewal Denied on Causation Ground

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Court: Supreme Court of New York, New York County - Defendant Mannington Mills Inc. moved for renewal of its previously denied motion for summary judgment, arguing the New York Court of Appeals’ Nemeth decision has since...more

Faegre Drinker Biddle & Reath LLP

What Dose Makes the Poison? Where Expert Cannot Say, Eleventh Circuit Affirms Summary Judgment

A central tenet of toxicology is that “the dose makes the poison.” Every chemical is toxic if enough of it is consumed, and every chemical has some dose – even if miniscule – at which it poses no significant risk. A chemical...more

Goldberg Segalla

Clutch Manufacturer Obtains Summary Judgment on Medical Causation Grounds

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Court: Supreme Court of the State of New York, Nassau County - In this asbestos action, plaintiff Donna Daniell alleged asbestos exposure from working near auto mechanics, including her husband, Robert, while they used...more

Husch Blackwell LLP

Frequency, Regularity, Proximity: The Western District of Washington Requires More Than a Product’s Presence to Find Causation

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On March 9, 2023, a federal judge granted summary judgment on causation to three manufacturers of asbestos-containing products in a maritime lawsuit arising from the death of Thomas Deem from mesothelioma. The judge held that...more

Goldberg Segalla

Lack of Causation Entitles Valve/Gasket Defendants to Summary Judgment

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Court: United States District Court for the Western District of Washington - This case arises out of the death of decedent Thomas Deem from mesothelioma, which the plaintiff alleges was caused by the decedent’s exposure...more

Faegre Drinker Biddle & Reath LLP

Texas Supreme Court Refocuses on Causation and Affirms Summary Judgment in Herbicide Drift Case

The question of whether a particular application of herbicide on one property caused damage on another’s property requires expert testimony. When a plaintiff claims that herbicide drift caused reduced crop yields, it is not...more

Husch Blackwell LLP

Nemeth Is the Law – Causation in NYCAL Talc and Asbestos Cases

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We previously reported on Nemeth v. Brenntag North America, et al., 38 N.Y.3d 336 (Ct. App. NY Apr. 26, 2022), a landmark case in which the New York’s Court of Appeals reversed a $16,500,000 asbestos jury verdict because the...more

Goldberg Segalla

Talcum Powder Defendant Fails to Meet Summary Judgment Burden on Medical Causation

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Supreme Court of New York, New York County, September 22, 2022 - In this NYCAL action, Decedent Maryann Purser (“Decedent”) alleged that she developed pleural mesothelioma through the use of Cashmere Bouquet talcum...more

Harris Beach Murtha PLLC

New York’s Appellate Division Affirms Summary Judgment Based on Lack of Specific Causation of Toxic Exposure to Gas

New York’s Appellate Division, First Department affirmed a decision of the Bronx County Supreme Court, which precluded plaintiff’s expert evidence submitted in opposition to a summary judgment motion and following a Frye...more

Harris Beach Murtha PLLC

Update to Legal Alert: Summary Judgment Reversed In Toxic Tort Matter Involving Bladder Cancer and Exposure to O-Toluidine

Harris Beach Murtha PLLC on

We previously wrote about a federal magistrate judge’s report and recommendation denying exclusion of Plaintiffs’ specific causation expert and granting Defendants’ motions for summary judgment in a toxic tort suit arising...more

Faegre Drinker Biddle & Reath LLP

Failure to Fully Disclose Expert Opinions Results in Summary Judgment

Federal Rule of Civil Procedure 26(a)(2) requires retained expert witnesses to provide an expert report which gives “a complete statement of all opinions the witness will express and the basis and reasons for them.” Fed. R....more

Steptoe & Johnson PLLC

Has the Gate Swung Open? – Recent PA Frye Ruling

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The Pennsylvania Superior Court recently issued an opinion in Walsh v. BASF Corp. addressing the gatekeeper role of the trial judge when reviewing and ruling on the admissibility of expert causation opinions. The PA Superior...more

Beveridge & Diamond PC

Toxic Tort & Product Liability Quarterly Vol. 9, No. 3, August 2016

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California Appellate Court Upholds “Every Exposure” Theory - Deferring to the role of a jury in resolving questions of competing scientific theories, a California appeals court upheld a trial court’s ruling allowing...more

Beveridge & Diamond PC

Michigan Court Finds Expert Testimony Not Necessary to Show Link Between Chemical Exposure and Injury

Issuing an opinion that could lower the bar for proving toxic tort causation, the Michigan Court of Appeals held that direct expert testimony may not be necessary to prove causation in a toxic tort case and that a plaintiff...more

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