General Electric Co. v. Joiner case brief summary
522 U.S. 136 (1997)
CASE FACTS
After the worker was diagnosed with cancer, he brought a products liability action, claiming exposure to polychlorinated biphenyls (PCBs), furans, and dioxins produced by the companies caused his cancer. After finding the testimony of the worker's experts speculative and unsupported, the district court excluded their testimony and entered summary judgment for the companies upon ruling that, although there was a genuine issue as to whether the worker was exposed to PCBs, there was no factual dispute that he had not been exposed to furans and dioxins.
PROCEDURAL HISTORY
The court of appeals reversed, applying "a particularly stringent standard of review" in ruling that the exclusion of expert testimony was error, in light of the Daubert doctrine, and finding that there was a genuine issue as to whether the worker had been exposed to furans and dioxins. The companies sought review of the expert testimony ruling only.
DISCUSSION
In reversing the ruling on that issue, the Supreme Court held that the proper standard of review was abuse of discretion and it was within the district court's discretion to exclude unreliable expert testimony.
CONCLUSION
The judgment of the court of appeals applying a standard of review greater than abuse of discretion was reversed, the exclusion of expert testimony by the district court under the proper abuse of discretion standard was upheld, and the case was remanded for further consideration given the unchallenged ruling of the court of appeals that a genuine issue of fact precluded summary judgment.
See Also: Daubert Standard.
Suggested Study Aids For Tort Law
522 U.S. 136 (1997)
CASE SYNOPSIS
Petitioner companies were
granted a writ of certiorari to review the judgment of the United
States Court of Appeals for the Eleventh Circuit that reversed a
summary judgment for the companies upon application of "a
particularly stringent standard of review" to the district
court's exclusion of expert testimony offered by respondent worker in
a products liability action and upon ruling that a factual dispute
precluded summary judgment.CASE FACTS
After the worker was diagnosed with cancer, he brought a products liability action, claiming exposure to polychlorinated biphenyls (PCBs), furans, and dioxins produced by the companies caused his cancer. After finding the testimony of the worker's experts speculative and unsupported, the district court excluded their testimony and entered summary judgment for the companies upon ruling that, although there was a genuine issue as to whether the worker was exposed to PCBs, there was no factual dispute that he had not been exposed to furans and dioxins.
PROCEDURAL HISTORY
The court of appeals reversed, applying "a particularly stringent standard of review" in ruling that the exclusion of expert testimony was error, in light of the Daubert doctrine, and finding that there was a genuine issue as to whether the worker had been exposed to furans and dioxins. The companies sought review of the expert testimony ruling only.
DISCUSSION
In reversing the ruling on that issue, the Supreme Court held that the proper standard of review was abuse of discretion and it was within the district court's discretion to exclude unreliable expert testimony.
CONCLUSION
The judgment of the court of appeals applying a standard of review greater than abuse of discretion was reversed, the exclusion of expert testimony by the district court under the proper abuse of discretion standard was upheld, and the case was remanded for further consideration given the unchallenged ruling of the court of appeals that a genuine issue of fact precluded summary judgment.
See Also: Daubert Standard.
Suggested Study Aids For Tort Law
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