Daubert v. Merrell Dow Pharmaceuticals case brief summary
F: On remand from the US Supreme Court, SJ was entered in D's favor by the TC in P's action against D for damages based on a claim that the drug caused Ps birth defects. TC excluded testimony of P's experts that the drug manufactured by D caused the birth defects.
P suffered limb reduction birth defects. They sued D, alleging that the birth defects were caused by their mothers' ingestion of drug manufactured by D.
I: whether expert scientific testimony was admissible to prove that drug caused ps' injury
R: expert scientific testimony was not admissible to prove that drug caused p's birth defects.
FRE do not require general acceptance of a scientific technique in the scientific community as an absolute prerequisite
to admissibility of expert witness testimony
1. Scientific standard of evidence
2. statistically doubles the rate in order to prove causation
Federal standard of evidence (in federal court)
A: The court applied the two-part Daubert standard. In the first part of the inquiry, the court found that none of Ps' experts based their testimony on preexisting or independent research, published their work in scientific journals, or adequately explained their methodology. The court concluded that the proffered scientific testimony was not derived by scientific method. In the second prong of inquiry, the court concluded that Ps' proffered expert testimony was insufficient to establish causation as a matter of law.
C: affirmed TC's grant of summary judgment to D.
Co: Ps' case involved a difficult causation issue because scientific knowledge had not advanced enough to explain precisely whether and how the drug interfered with limb development.
Ps relied on statistical evidence and proffered experts' opinions that did not reflect the consensus of the scientific community.
F: On remand from the US Supreme Court, SJ was entered in D's favor by the TC in P's action against D for damages based on a claim that the drug caused Ps birth defects. TC excluded testimony of P's experts that the drug manufactured by D caused the birth defects.
P suffered limb reduction birth defects. They sued D, alleging that the birth defects were caused by their mothers' ingestion of drug manufactured by D.
I: whether expert scientific testimony was admissible to prove that drug caused ps' injury
R: expert scientific testimony was not admissible to prove that drug caused p's birth defects.
FRE do not require general acceptance of a scientific technique in the scientific community as an absolute prerequisite
to admissibility of expert witness testimony
1. Scientific standard of evidence
2. statistically doubles the rate in order to prove causation
Federal standard of evidence (in federal court)
A: The court applied the two-part Daubert standard. In the first part of the inquiry, the court found that none of Ps' experts based their testimony on preexisting or independent research, published their work in scientific journals, or adequately explained their methodology. The court concluded that the proffered scientific testimony was not derived by scientific method. In the second prong of inquiry, the court concluded that Ps' proffered expert testimony was insufficient to establish causation as a matter of law.
C: affirmed TC's grant of summary judgment to D.
Co: Ps' case involved a difficult causation issue because scientific knowledge had not advanced enough to explain precisely whether and how the drug interfered with limb development.
Ps relied on statistical evidence and proffered experts' opinions that did not reflect the consensus of the scientific community.
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