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January 15, 2025

A case about hydrogen sulfide exposure foundered for lack of proof as to “general causation.” In examining the materials cited by the plaintiff’s expert on that point, the Court observed:

“Although we view the reliability of expert testimony ‘in light of the totality of the evidence,’ ‘[t]he totality of the evidence cannot prove general causation if it does not meet the standards for scientific reliability established by Havner. A plaintiff cannot prove causation by presenting different types of unreliable evidence.'”

Newsome v. Int’l Paper Co., No. 24-20126 (Jan. 11, 2025).

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