In Wannall v. Honeywell, Inc., 775 F.3d 425 (D.C. Cir. 2014) (No. 13-7185), the District of Columbia Circuit Court of Appeals addressed the dismissal of an asbestos lawsuit based on a change in the Virginia state law standard for proving liability.  Initially, plaintiff had defeated defendant’s summary judgment motion at the close of discovery by submitting expert testimony that plaintiff’s exposure to defendant’s asbestos product was “a substantial cause” of his illness.  Subsequent to that decision, but before trial, the Supreme Court of Virginia issued a decision rejecting the “substantial cause” standard in favor of a standard requiring plaintiffs to demonstrate that “exposure to the defendant’s product alone must have been sufficient to have caused plaintiff’s harm.”  The defendant renewed its summary judgment motion under this new standard; the plaintiff responded by standing on the prior expert submissions and arguing that the new Virginia decision did not make a substantive change in Virginia law.  The district court disagreed and held the prior expert submissions were insufficient under the new standard, and the D.C. appellate court affirmed that decision.