Vaughn v. Granite City Steel Division of National Steel Corp.

Under Illinois law, proximate cause is a term of art which encompasses the distinct concepts of cause in fact and legal cause. A plaintiff who fails to establish the first of these elements, cause in fact, has not sustained his burden of making a prima facie case in negligence. Cause in fact can be established only where there is a reasonable certainty that the defendant’s conduct caused the injury. If no facts are put forth by the plaintiff to show that the injuries sustained were caused or contributed to by an act or omission of the defendant, a judgment based on such evidence cannot be…