In Holcomb v. Georgia Pacific, LLC, 289 P.3d 188 (Nev. 2012) (No. 56510), the Nevada Supreme Court addressed the question of what standard to adopt for proving causation in asbestos exposure mesothelioma cases.  First, the court considered the California Supreme Court’s test that “plaintiffs may prove causation in asbestos-related cancer cases by demonstrating that the plaintiff’s exposure to defendant asbestos-containing products in reasonable medical probability was a substantial factor in contributing to the aggregate dose of asbestos the plaintiff inhaled or ingested, and hence to the risk of developing of asbestos-related cancer.”  The Nevada court deemed that test too easy to satisfy and thus rejected it as not providing sufficient protection to defendant manufacturers.  The court next considered the Texas Supreme Court’s substantial factor test, which requires the plaintiff to present evidence of regular exposure and also “defendant-specific evidence relating to the approximate dose to which plaintiff was exposed, coupled with the evidence that the dose was a substantial factor in causing the asbestos-related disease.”  The Nevada court rejected this test as being too difficult for plaintiffs to prove.  Finally, the court considered the “frequency, regularity, proximity” test adopted by the Pennsylvania Supreme Court and the Fourth Circuit.  This test requires the plaintiff to prove exposure to a specific product attributable to the defendant “on a regular basis over some extended period of time” and “in proximity to where the plaintiff actually worked.”  The court viewed this standard as striking the best balance between the interests of plaintiffs and defendants.  Based upon this test, the court ruled that summary judgment was appropriate only for one of the defendants, as to which plaintiff had shown no exposure to its product.