In Falcon v. Memorial Hosp, 436 Mich. 443; 462 N.W.2d 44 (1990), rev'd in part on other grounds 437 Mich. 926, 467 N.W.2d 25 (1991), superseded by statute as stated in Weymers v. Khera, 454 Mich. 639; 563 N.W.2d 647 (1997), the plaintiff suffered from a fatal amniotic fluid embolism during the birth of her child. The plaintiff's expert witness stated that had an intravenous line been connected to the plaintiff before the onset of the embolism, the plaintiff would have had a 37.5 percent chance of survival. Falcon, 436 Mich. at 454-455. The Supreme Court held that the loss of a 37.5 percent chance of living was actionable under Michigan law. Falcon, 436 Mich. at 470.