Cause-in-Fact in Missouri: A Return to Normalcy

Abstract

In order to establish liability in most tort actions, a plaintiff must show that the defendant caused the injury or harm in question. This Note focuses on the cause-in-fact requirement discussed in the Missouri Supreme Court case, Callahan v. Cardinal Glennon Hospital. In Callahan , the court dispelled much of the confusion that has plagued Missouri cause-in-fact analysis.\u27 The court clearly expounded the test for cause-in-fact questions. Furthermore, the court explained the exception to the basic test, and clarified Missouri law regarding this essential element of tort liability

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