Susan E. Brice and Vince Angermeier on Causation in Toxic Torts Abstract Concepts of “substantial factors,” “any exposure,” and “de minimis” contact have long-supported claims brought by toxic tort plaintiffs against manufacturers. They have furthered tort actions against defendants based on the “cumulative expo-sure” theory, particularly in the asbestos arena, even when a single fiber could not be connected to a specific defendant. But a 2017 Seventh Circuit decision dealing with Illinois law is part of a trend toward tightening up these standards. This article discusses the various cases on this threshold issue as the authors ponder whether this is a movement that needs some pushing. Authors Susan E. Brice (sb@nijmanfranzetti.com) is a partner at Nijman Franzetti, LLP. She has litigated state and federal disputes and has counseled clients on complicated scientific issues arising in environmental law, toxic torts, and product liability. Susan [...]