With Spring Training well underway, we took notice of the solid base hit delivered last month by the Northern District of California in La Paz v. Bayer Healthcare LLC, No. C 15-03995, 2016 U.S. Dist. LEXIS 13058 (N.D. Cal. Feb. 2, 2016). The district court dismissed all the plaintiff’s claims, mainly on preemption grounds, but the more interesting part of the order is the district court’s treatment of causation.