California Reaffirms The Requirement of Proof of Exposure:
Cadlo v. Owens-Illinois

photo-1ABOUT THE AUTHOR Shawn D. Parrish is a partner at Morgenstein & Jubelirer LLP in San Francisco. He was appellate counsel to Owens-Illinois in the Cadlo case. He was also trial counsel to Owens-Illinois in the Chavers v. Gatke case, and his firm was counsel to Owens-Illinois in the appeal of Rutherford v. Owens-Illinois, both of which cases are discussed in this article.

A recent decision of the California Court of Appeal, Cadlo v. Owens-Illinois, Inc., 23 Cal.Rptr.3d 1 (2004), rejected three separate arguments for holding the defendant liable for the plaintiff's asbestos-related injuries caused by products …