There is nothing in the entire field of law which has called forth more disagreement, or upon which the opinions are in such a welter of confusion’ than causation.” Templemire v. W&M Welding, Inc., No. SC 93132, 2014 WL 1464574, at*9 (Mo. banc April 15, 2014) (quoting Prosser and Keeton on Torts, § 41 at 263 (5th ed. 1984). In a 5 – 2 decision, the Missouri Supreme Court overruled its own precedent on the appropriate causation standard for workers’ compensation retaliation claims. Id. Plaintiffs no longer need to prove that filing a workers’ compensation claim was the “exclusive cause” of an adverse employment action. They only need to prove that the workers’ compensation claim was a “contributing factor” in their employer’s decision to take an adverse employment action against them.