Kumho Tire Company, Ltd. v. Carmichael case brief summary
526 U.S. 137 (2010)
On writ of certiorari, petitioner tire
maker appealed the judgment of the United States Court of Appeals for
the Eleventh Circuit, which reversed the district court's decision to
exclude the testimony of respondent customers' tire expert because
the expert relied on experience-based observations instead of the
application of scientific principles.
CASE FACTS Respondent customers sued petitioner
tire maker after a tire blew out on their minivan. Respondents'
expert in tire failure analysis intended to testify that a defect in
the tire's manufacture or design caused the blow-out. The district
court excluded the expert's testimony after an examination of
Daubert's reliability-related factors. The court of appeals reversed.
A trial judge could have considered Daubert's
specific factors to assess reliability and to determine
However, the Court emphasized that while a trial judge
may consider those factors, the factors may or may not apply in a
The Court found that some of Daubert's questions
were helpful in evaluating the reliability even of experience-based
The Court concluded that refusal to admit the testimony of
respondents' expert was not an abuse of discretion where no evidence
existed that any other tire expert accepted the methodology of
CONCLUSION The Court reversed the judgment of the
court of appeals which allowed the testimony of respondent customers'
tire expert because the court was permitted to ask reliability
questions even though respondents' expert relied on experience-based
observations. The standards of evidentiary reliability applied to all
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