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We’ve never seen a case quite like Michaels v. Genzyme Corp., 2023 WL 8828003 (S.D. Ill. Dec. 21, 2023), before, and we hope we don’t again.  Michaels took the “proximate” out of proximate cause.

Here’s why we say that.  Michaels was filed in 2023 over “a paternity test that was conducted in 1989.”  Id.