Ga. Court Affirms Summary Judgment for Defendant, Rejects 'Any Exposure' Testimony

ATLANTA -- A Georgia appellate court has affirmed an award of summary judgment for Union Carbide, agreeing with the trial court's assessment that the plaintiff's expert testimony did not satisfy admissibility standards. Butler, et al. v. Union Carbide Corp., et al., No. A11A0481 (Ga. Ct. App.).

In the June 15 opinion, the Georgia Court of Appeals found fault with the plaintiff's specific causation expert, saying that his "any exposure" theory of causation did not take into account each product with which the decedent worked, but rather the cumulative occupational exposure.

Laura Butler asserted the claims on behalf of her …