A federal judge in Philadelphia has tossed some cases in the multidistrict asbestos litigation against a group of defendants he said couldn’t be held liable for the fact that their non-asbestos-containing products were later used in asbestos-containing products handled by the plaintiffs.

In a footnote to his opinion in Conner v. Alfa Laval Inc. , U.S. District Court Judge Eduardo C. Robreno of the Eastern District of Pennsylvania outlined the shift in asbestos litigation in the country away from those that actually made asbestos products and toward any defendants whose parts may have wound up containing asbestos.