**Illinois Appellate Court / Civil Jury Instructions | 1st District**

**Evard v. Monsanto Co., 2025 IL App (1st) 241235 (November 13, 2025) 4th Division / Cook County (NAVARRO) - Affirmed.**

The plaintiffs filed a lawsuit alleging that an herbicide manufactured by the defendant caused them to develop non-Hodgkin's lymphoma. A jury rendered a verdict in favor of the defendant, and the plaintiffs subsequently appealed.

On appeal, the plaintiffs argued that the trial court made several errors, specifically: providing jurors with the short-form pattern jury instruction on proximate cause, failing to remove a potentially biased juror, and denying their request for a continuance or mistrial when their two lead trial attorneys contracted COVID-19 during the trial and were unable to participate further.

The appellate court affirmed the trial court's decision, concluding that while it might have been preferable to use the long-form version of the proximate cause instruction, the court could not determine that the trial court abused its discretion based on the circumstances of the case. The court also found that there was no abuse of discretion in retaining a juror who expressed concerns about impartiality, as the juror assured the court he would base his verdict solely on the facts and the law. Additionally, the appellate court supported the trial court's decision to deny the plaintiffs' request for an indefinite continuance, noting that the plaintiffs had not taken advantage of opportunities to leverage technology to participate in the trial and that they remained represented by experienced attorneys. (MIKVA and MITCHELL, concurring)