The majority of jurisdictions have refused to recognize "loss of chance" as a doctrine lessening required proof of causation. See, e.g., Weymers v. Khera, 454 Mich. 639, 563 N.W.2d 647, 653 (Mich. 1997) (affirming summary judgment for physician where plaintiff had only "thirty to forty percent chance" of avoiding injury, and holding that "no cause of action exists for the loss of an opportunity to avoid physical harm"); Jones v. Owings, 318 S.C. 72, 456 S.E.2d 371, 374 (S.C. 1995) ("After a thorough review of the 'loss of chance' doctrine, we decline to adopt the doctrine . . . ."); Kilpatrick v. Bryant, 868 S.W.2d 594, 602 (Tenn. 1993) ("the loss of chance doctrine is fundamentally at odds with the requisite degree of medical certitude necessary to establish a causal link between the injury of a patient and the tortious conduct of a physician"); Kramer v. Lewisville Mem. Hosp., 858 S.W.2d 397, 405 (Tex. 1993) ("The more likely than not standard is . . . a fundamental prerequisite to an ordered system of justice."); Dumas v. Cooney, 235 Cal. App. 3d 1593, 1 Cal. Rptr. 2d 584, 592 (Cal. Ct. App. 1991) ("We therefore decline to establish a more lenient standard of causation . . . to account for the theory of lost chance."); Fennell v. Southern Md. Hosp. Ctr., 320 Md. 776, 580 A.2d 206, 211 (Md. 1990) ("We are unwilling to relax traditional rules of causation and create a new tort allowing full recovery for causing death by causing a loss of less than a 50% chance of survival. In order to demonstrate proximate cause, the burden is on the plaintiff to prove by a preponderance of the evidence that "it is more probable than not that defendant's act caused his injury."); Pillsbury-Flood v. Portsmouth Hosp., 128 N.H. 299, 512 A.2d 1126, 1130 (N.H. 1986) (rejecting as "ill-advised" a proposed "relaxed" causation standard); Gooding v. University Hosp. Bldg., 445 So. 2d 1015, 1020 (Fla. 1984) ("We agree with the majority rule . . . and hold that a plaintiff in a medical malpractice action must show more than a decreased chance of survival . . . plaintiff must show that the injury more likely than not resulted from the defendant's negligence in order to establish a jury question on proximate cause.").