Law School Case Brief
Kumho Tire Co. v. Carmichael - 526 U.S. 137, 119 S. Ct. 1167 (1999)
Daubert's general holding--setting forth the trial judge's general "gatekeeping" obligation--applies not only to testimony based on "scientific" knowledge, but also to testimony based on "technical" and "other specialized" knowledge. Fed. Rule Evid. 702. A trial court may consider one or more of the more specific factors that Daubert mentioned when doing so will help determine that testimony's reliability. But, the test of reliability is "flexible," and Daubert's list of specific factors neither necessarily nor exclusively applies to all experts or in every case. Rather, the law grants a district court the same broad latitude when it decides how to determine reliability as it enjoys in respect to its ultimate reliability determination.
When a tire on the vehicle driven by respondent Patrick Carmichael blew out and the vehicle overturned, one passenger died and the others were injured. Respondents, the survivors and the decedent's representative, brought a diversity action in federal district court against the tire's maker and its distributor, petitioner Kumho Tire Co., claiming that the tire that failed was defective. They rested their case in significant part upon the depositions of a tire failure analyst, Dennis Carlson, Jr., who intended to testify that, in his expert opinion, a defect in the tire's manufacture or design caused the blow out. The district court excluded Carison's testimony after an examination of Daubert's reliability-related factors. The court of appeals reversed.
Did the district court’s refusal to admit Carlson's expert opinion constitute an abuse of discretion?
The Supreme Court of the United States held that the Daubert standard of evidentiary reliability was not limited to scientific testimony but extended to all expert testimony. A trial judge could have considered Daubert's specific factors to assess reliability and to determine admissibility. However, the Court emphasized that while a trial judge may consider those factors, the factors may or may not apply in a particular case. The Court found that some of Daubert's questions were helpful in evaluating the reliability even of experience-based testimony. The Court concluded that refusal to admit the testimony of Carlson was not an abuse of discretion where no evidence existed that any other tire expert accepted the methodology of Carlson.
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