Craig Liljestrand CDLB Column: Ohio Supreme Court Determines R.C. 2307.96 'Substantial Factor' cannot be met through 'Cumulative-Exposure Theory'
In The News | 1 min read
Apr 3, 2018
Hinshaw partner Craig Liljestrand has published his latest Chicago Daily Law Bulletin column titled "Cumulative asbestos effect loses out." The article analyzes the case of Schwartz v. Honeywell International Inc., Slip Opinion No. 2018-Ohio-474 (Feb. 8, 2018), where the Ohio Supreme Court was called upon to determine whether the "statutory construction of R.C. 2307.96, a 'substantial factor' requirement may be met through a 'cumulative-exposure theory.'"
Liljestrand discusses the court's decision, in which the Court found that the "cumulative exposure" theory is incompatible with the plain language of the statute. First, R.C. 2307.96 requires an individualized determination for each defendant; second, the theory conflicts with the statutory requirement that substantial causation be measured based on the manner, proximity, length and duration of the exposure; and third, it does not consider the relationship different exposures may have to the overall dose to which an individual is exposed.
Read "Cumulative asbestos effect loses out" (PDF)
You can also read "Cumulative asbestos effect loses out," on the Chicago Daily Law Bulletin website (subscription required)
Related People
Related Capabilities
Related Locations
Featured Insights

Webinar
Apr 29, 2026
When a Cyber Breach Hits: Cybersecurity, Privacy, and Compliance

In The News
Apr 29, 2026
Lauren Campisi Featured in the 20th Anniversary of Louisiana Super Lawyers Magazine

In The News
Apr 28, 2026
Matt Henderson Provides Media Insights as Conflict of Interest Lawsuits Target Law Firms

In The News
Apr 28, 2026
Akeela White Analyzes US House Hearing on Credit Reporting Compliance Reforms

In The News
Apr 24, 2026
Michael Dowell Reviews New PBM Reform Reshaping Pharmacy Reimbursement

Lawyers for the Profession® Alert
Apr 21, 2026
When Does a Client’s Duty to Investigate Begin? Lessons from a Time-Barred Malpractice Case

Press Release
Apr 20, 2026
Tom Kuzmanovic Selected for BizTimes Milwaukee 2026 Notable Leaders in Law

Press Release
Apr 17, 2026
André Sesler Elected to the Board of Trustees of the University of Florida Law Center Association

Hinshaw Alert
Apr 17, 2026
Q&A: How to Submit Your IEEPA Refund Claim as CAPE Portal Launches April 20, 2026




