Schultz ex rel. Estate of Schultz v. Akzo Nobel Paints, LLC

1 Analyses of this case by attorneys

  1. Chicago Federal Court Bars Expert Testimony Espousing the “Any Exposure” Theory

    Wilson Elser LLPAnthony GoldnerJanuary 13, 2015

    The court found that the approach taken by the plaintiff’s experts was “unacceptable” for a causation expert. The court was persuaded by the reasoning in Schultz v. Akzo Nobel Paints, LLC, 721 F.3d 426, 433-34 (7th Cir. 2013) and Smith v. Ford Motor Co., No. 2:08-cv-630 (D. Utah Jan. 18, 2013). In Schultz, the Seventh Circuit observed that “the notion that it is theoretically possible that any amount of exposure could cause injury is different from an opinion that the particular level of dosage experienced by a plaintiff was sufficient to cause his or her particular injury.”