Wannall v. Honeywell International, Inc.

Tyler, a brake repairman exposed to asbestos from Bendix brakes (Honeywell's (defendant) predecessor) as well as separately during Navy service and at Fort Belvoir, developed and died of mesothelioma; his estate's expert, Dr. Markowitz, initially opined any one of the three exposures was sufficient to cause the disease, and the district court denied Honeywell's summary judgment motion under the then-governing substantial-contributing-factor causation standard. While the case was pending, Virginia's high court abrogated that standard in favor of requiring proof of a specific causative dose threshold compared to the plaintiff's actual exposure, prompting the expert to file a supplemental declaration and Honeywell to renew its summary judgment motion.