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.' 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.
Christopher M. Hohn,
Cause-in-Fact in Missouri: A Return to Normalcy,
59 Mo. L. Rev.
Available at: https://scholarship.law.missouri.edu/mlr/vol59/iss4/4