In Weymers v. Khera, 454 Mich. 639; 563 N.W.2d 647 (1997), the Supreme Court discussed Falcon and the lost opportunity doctrine. The Court noted, "Stated another way, the lost opportunity doctrine permits a plaintiff to maintain an action for malpractice when the malpractice denied the plaintiff an opportunity to avoid the injury, even where the opportunity was fifty percent or less." Id. at 648, n 13. The Court stated that there are three alternative approaches to the lost opportunity doctrine: (1) the pure lost chance approach; (2) the proportional approach; (3) the substantial possibility approach. Id. at 650. The Court further explained that each approach lowers the standard of causation and allows a plaintiff to recover without establishing cause in fact. Id. The Court stated the following with respect to the substantial possibility approach: The last approach, the substantial possibility approach, was adopted by this Court in Falcon for wrongful death cases. It also is a variation of the pure lost chance approach. Under this approach, the plaintiff must show that there is a substantial possibility that the defendant's negligence caused his injury. See Falcon, supra at 469. It is unclear what constitutes a "substantial possibility." See id. at 470 (holding that a 37.5 percent chance of survival was substantial, but refusing to state what constitutes a threshold showing of substantial). It is clear, however, that it does not have to be more than fifty percent. Id. Thus, the substantial possibility approach is identical to the other approaches to the extent that each approach allows a plaintiff to recover for his injury even though it was more likely than not that he would have suffered the injury if the defendant had not been negligent. Weymers, supra at 651.