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Before admitting scientific expert testimony, the trial court must conclude, pursuant to the Federal Rules of Evidence, that the proposed testimony constitutes: (1) scientific knowledge that (2) will assist the trier of fact to understand or determine a fact in issue. This standard is a flexible one whose overarching subject is the scientific validity--and thus the evidentiary relevance and reliability--of the principles that underlie a proposed submission. The court's focus, of course, must be solely on principles and methodology, not on the conclusions that they generate.
This case involved a dispute between competing breeders of corn seed. The district court awarded $ 46,703,230.00 to Pioneer Hi-Bred International based on Holden Foundation Seeds, Inc.'s misappropriation of the genetic make-up of certain seed corn. Holden contested the district court's liability determination and damage award on numerous grounds. Pioneer cross-appealed from the district court's denial of prejudgment interest. Much of Holden's argument before attacked Pioneer's scientific evidence as inadequate to support the district court's judgment. A threshold issue, however, was Holden's assertion that the district court erred in admitting the scientific evidence relating to electrophoresis, liquid chromatography, and growout testing.
Did the district court err in admitting the scientific evidence relating to electrophoresis, liquid chromatography, and growout testing?
The court concluded that expert testimony was properly admitted under the Daubert standard. The trial court committed no error in admitting scientific evidence where the testimony constituted scientific knowledge that assisted it in understanding and determining material facts. Expert testimony on genetics and horticulture testing assisted the trial court in making its liability finding, as such testing established Holden’s possession of Pioneer’s protected material and played a significant role in evaluating Holden’s claims as to how it developed the contested lines. The damages award was affirmed where Holden’s sales figures and Pioneer’s productive capacity, profit history, and estimated lost profits provided a reasonable basis for the award.