Subject: Causation

Clearing the Weeds: The Ninth Circuit Confirms that There is Not (And Never Has Been) a Presumption of Admissibility in Its Case Law Addressing Rule 702

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The judge overseeing the In re Roundup Products Liability Litigation MDL once remarked that “When you [consider] Ninth Circuit law, you come away with a pretty strong feeling that the Ninth Circuit is more tolerant of shaky expert opinions than other circuits.”  But that was before the 2023 amendments to Federal Rule of Evidence 702, and appellate courts around the country have gradually been addressing how the amendments impact pre-amendment case law. The Ninth Circuit recently joined the ranks in a way, affirming that same judge’s exclusion of an expert’s causation opinion while harmonizing Ninth Circuit case law with the purposes of the 2023 amendments. The opinion is Engilis v. Monsanto Company, — F.4th —, 2025 WL 2315898 (9th Cir. 2025), and the headlines may come as a surprise to some.

The case-specific underpinnings of the holding are relatively straightforward. The plaintiff alleged that he developed cancer due to exposure to a product manufactured by the defendant. His expert, however, had failed to consider the plaintiff’s obesity as a potential cause of the cancer when conducting the differential etiology that formed his specific causation opinion. He tried to get around this omission by claiming that the plaintiff was not obese, and the plaintiff argued that this was a disputed fact because his plaintiff’s fact sheet was marked “negative” for obesity.  However, the expert failed to cite any medical records indicating that the plaintiff was not obese and did not engage with records that showed he was obese. Translated to Rule 702 terms, any opinion that the plaintiff was not obese was not “based on sufficient facts or data.”  So, the expert argued that obesity is not a risk factor for the kind of cancer at issue and thus did not need to be considered. But his report cited no support for that proposition, which he manufactured at the hearing on the defendant’s Rule 702 motion. The Ninth Circuit agreed with the district court that these issues rendered the expert’s specific causation opinion inadmissible.

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Defining the Limits of Lay Testimony in Complicated Products Cases

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“So when is a question too complicated for the jury?” That is the question the Third Circuit sought to answer recently in Slatowski v. Sig Sauer, Inc., ___ F. 4th ___, 2025 WL 2178533 (3d Cir. 2025), reversing a district court’s grant of summary judgment despite affirming its exclusion of the plaintiff’s causation experts. Ironically, the Third Circuit’s analysis of when an expert opinion is required is itself so nuanced that it may require expert interpretation. Upon close inspection, the Slatowski panel’s holding is not nearly as broad as the headings might suggest.

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Message Received – Delaware Follows Federal Rule of Evidence 702

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The Delaware Superior Court took the mass tort world by surprise with its May 31, 2024, refusal to exclude the plaintiffs’ experts’ causation opinions in the Zantac litigation, breaking with the federal MDL court’s prior exclusionary order and applying Delaware Rule of Evidence 702 “with a liberal thrust favoring admission.” The ruling was so unexpected that some outlets questioned whether Delaware courts would become a new preferred venue for mass tort plaintiffs. But, in a rare move, the Delaware Supreme Court granted the defendants’ request for interlocutory appeal — despite the Superior Court’s refusal to certify the order — and has now restored order, reversing the Superior Court’s decision and remanding for further proceedings. In re Zantac (Ranitidine) Litig., — A.3d —, 2025 WL 1903760 (Del. July 10, 2025).

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Double Take: Fifth Circuit’s Dual BELO Rulings Show Both General and Specific Causation Are Essential

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We previously blogged about a decision in the In re Deepwater Horizon BELO litigation – Ruffin v. BP Exploration & Production, Inc. – in which the Fifth Circuit affirmed summary judgment for defendants in an alleged chemical exposure case based solely on exclusion of the plaintiff’s expert testimony on general causation without reaching the experts’ specific causation opinions.   As it turns out, in another BELO case argued before the same panel on the same day, the panel analyzed the plaintiff’s experts’ specific causation opinions and declined to reach their general causation opinions. Williams v. BP Exploration & Production, — F.4th —, 2025 WL 1904153 (5th Cir. July 10, 2025). Notwithstanding the concerns we previously expressed about the Ruffin panel’s approach to general causation in isolation from specific causation, the Ruffin and Williams decisions provide a potent couplet illustrating that general causation and specific causation are two distinct steps in the analysis. Both must be proven in order for a plaintiff to make a prima facie case.

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Tort Reform is Top of Mind in 2025: Legislative Updates in Georgia, South Carolina, Louisiana and Arkansas

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The American Tort Reform Foundation’s list of “Judicial Hellholes” often are all-too-familiar jurisdictions for product liability defendants. Some states who are home to these infamous venues, often known for producing nuclear verdicts, have recently rallied for successful tort reform. In the most recent state legislative sessions, Georgia, South Carolina, Louisiana and Arkansas implemented tort reform bills which may serve to neutralize the nuclear verdicts coming out of their courts.

Georgia

Following several nuclear verdicts, including a $1.7 billion verdict in Hill v. Ford Motor Co. and a $2.5 billion verdict in Brogdon v. Ford Motor Co., Georgia has recognized the impact that excessive tort costs have on Georgia’s economy and its ability to attract businesses. Georgia Governor Brian Kemp unveiled a tort reform package in early 2025 that sought to address these issues.

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Fifth Circuit Clouds Threshold Dose Analysis in Ruffin v. BP

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Plaintiffs in toxic tort cases must prove both general and specific causation, generally through the testimony of experts. Experts must establish that a specific chemical exposure can (and did) cause the specific injury at issue. In order to make that showing, the plaintiff’s exposure must at least have exceeded the minimum harmful level of the chemical — the “threshold dose.” As the Eleventh Circuit made clear last year in its handling of In re Deepwater Horizon BELO litigation (which we discussed here), threshold dose is a concept that straddles general and specific causation. A more recent BELO case, Ruffin v. BP Exploration & Production, Inc., — F.4th —, 2025 WL 1367185 (5th Cir. May 12, 2025), shows how isolating an expert’s general causation opinion from its implications on specific causation can cloud the analysis.

In Ruffin, the plaintiff worked for five months as a clean-up worker following the Deepwater Horizon oil spill. He was diagnosed with prostate cancer five years later and sued the defendant, claiming he was exposed to chemicals that caused his cancer. He described two instances of exposure: one when oil splashed onto his face while travelling by boat and another when he fell in the water. The plaintiff had a known genetic risk for prostate cancer, but his expert claimed the oil exposures were a “second and necessary hit to initiate his prostate cancer.” The defendant moved to exclude the plaintiff’s causation expert, a genetic and molecular epidemiologist, under Federal Rule of Evidence 702. The district court had excluded both the expert’s general and specific causation opinions as unreliable, largely for failure to specify a threshold dose, and then granted summary judgment for want of admissible expert evidence.

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