Wednesday, December 18, 2013

Kumho Tire Company, Ltd. v. Carmichael case brief

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.

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.

  • On appeal, the Court 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 respondents' expert was not an abuse of discretion where no evidence existed that any other tire expert accepted the methodology of respondent's expert.

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 expert testimony.

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