Two recent decisions from the California Court of Appeal have created uncertainty regarding the defenses that defendants can rely on in asbestos and other toxic tort cases. In the most recent case, O'Neil v. Crane Co., Case No. B208225 (September 18, 2009), the Court of Appeal reversed the granting of a motion for non-suit in an asbestos-wrongful death case. Decedent Patrick O'Neil died of mesothelioma in 2005. His wife and children sued the manufacturers of pumps and valves that were installed on an aircraft carrier on which O'Neil had served as a Naval officer in the 1960s. Following the close of plaintiffs' evidence, the trial court granted the manufacturer's motion for non-suit.