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For example, Maryland and South Carolina trial courts dismissed similar claims, finding the Second Circuits approach in the New York case persuasive.12 On the other hand, the Colorado Supreme Court was persuaded by the reasoning in Hawaii.13 These cases present difficult and untested questions, particularly around causation, and John Dernbach and Pat Parenteau sum up the situation well: The takeaway from these early decisions is that climate litigation presents a host of challenging legal and factual issues that will take some time to sort out

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