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The fundamental requirements of Tex. R. Evid. 702, reliability and relevance, are applicable to all expert testimony offered under that rule. All expert testimony must be shown to be reliable before it is admitted.
Plaintiff family sought personal injury and wrongful death damages, alleging design defects in the accelerator and seat belt system. The trial court had rejected the expert testimony offered in support of their claims, and had granted summary judgment to the defendant manufacturer and the seller of plaintiffs’ vehicle. The Court of Appeals affirmed the summary judgment granted to defendants. Plaintiffs challenged the decision.
Did the trial court err in rejecting plaintiffs’ expert testimony, thereby making the grant of summary judgment in favor of defendants an error?
The court affirmed the lower court's affirmance of a grant of summary judgment to defendants, vehicle manufacturer and seller, finding no abuse of discretion in holding that an expert on accelerators was not qualified to testify and that a seat belt expert's testimony was not scientifically reliable. While the trial court erred in disregarding the qualifying experience of the seat belt expert, plaintiff family failed to establish it was reliable.