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Admissibility Daubert Standards Expert Testimony

Faegre Drinker Biddle & Reath LLP

Same Song, Different Verse — Causation Experts for Second Group of Bellwether Plaintiffs Excluded for Same Reason as First Group’s...

Multidistrict litigation is meant to “promote the just and efficient conduct” of actions “involving one or more common questions of fact” by transferring those actions to a single district court “for coordinated or...more

Faegre Drinker Biddle & Reath LLP

California Supreme Court Walks Middle Ground on Warnings Causation but Reaffirms Learned Intermediary Doctrine in Himes

As we reported in April, the United States Court of Appeals for the Ninth Circuit certified a question on California’s Learned Intermediary Doctrine in Himes v. Somatics, LLC, 2022 WL 989469 (9th Cir. Apr. 1, 2022). The...more

Faegre Drinker Biddle & Reath LLP

Northern District of Illinois Holds that Seventh Circuit Precedent is Incompatible with Rule 702 as Amended

In explaining the December 2023 amendments to Federal Rule of Evidence 702, the Advisory Committee called out several ways in which “many courts” had “incorrectly” applied Rule 702 and failed to adequately discharge their...more

Faegre Drinker Biddle & Reath LLP

Old Habits Die Hard: First Circuit Cites Newly Amended Language of FRE 702 But Follows Abrogated Precedent Instead

The longer and more frequently a principle is repeated by the courts, the more difficult it can be for courts to acknowledge change. As illustrated by the First Circuit’s opinion in Rodriguez v. Hospital San Cristobal, Inc.,...more

Marshall Dennehey

Rule 702 Revamped Once Again

Marshall Dennehey on

Expert testimony is the tool that enables litigators to elucidate concepts that require scientific, technical or specialized knowledge. However, a proponent cannot introduce expert testimony without demonstrating under F.R.E....more

Faegre Drinker Biddle & Reath LLP

Amended FRE 702 Arrives in MDL Practice: S.D.N.Y. Excludes Plaintiffs’ Experts in Acetaminophen MDL

The Committee Notes to the newly implemented amendments to Federal Rule of Evidence 702 make clear that the “[j]udicial gatekeeping” of expert evidence is “essential.” Federal courts in New York have played an important role...more

Genova Burns LLC

New Jersey Supreme Court Rules Drug Recognition Expert Testimony Admissible Under the Daubert-Accutane Standard

Genova Burns LLC on

On November 15, 2023, the New Jersey Supreme Court released its decision on the much anticipated issue of whether Drug Recognition Expert (DRE) testimony is admissible under New Jersey Rule of Evidence 702. The Court...more

Faegre Drinker Biddle & Reath LLP

Something to Celebrate: A Brief Guide to the FRE 702 Amendments

Fun fact: There are 23 holidays that can be celebrated today, December 1st. Some, like Rosa Parks Day and World AIDS Day, are solemn and serious. Others are silly and fun, like National Peppermint Bark Day and National...more

IMS Legal Strategies

Working with Experts Under the New 702 Rule

IMS Legal Strategies on

On June 7, 2022, the Judicial Conference Committee on Rules of Practice and Procedure approved amendments to several of the Federal Rules of Evidence—including Rule 702, which governs the admissibility of expert witness...more

Faegre Drinker Biddle & Reath LLP

Courts Are Citing the Rule 702 Amendments – And Litigants Should, Too

Though the pending amendments to Federal Rule of Evidence 702 have not taken effect officially yet, courts already have begun to cite them. Early signs indicate the potential that, consistent with the comments by the Advisory...more

Bradley Arant Boult Cummings LLP

Court Allows Expert Testimony Regarding Measured Mile Analysis Comparing Work on Different Projects

Loss of productivity damages are commonly estimated using a “measured mile” analysis, which compares unimpacted construction work to work which has been disrupted to determine the cost impact of the disruption. Such analyses...more

Faegre Drinker Biddle & Reath LLP

Court Finds Ship Has Sailed for Seaman to Disclose Expert’s Opinions, Resulting in Summary Judgment

Discovery deadlines exist for a reason. Although there are exceptions to every rule – and often a rule dictating how to handle such exceptions – litigants in federal court are expected to show their evidentiary cards in a...more

IMS Legal Strategies

Working with Experts after Proposed 702 Rule Changes

IMS Legal Strategies on

On June 7, 2022, the Judicial Conference Committee on Rules of Practice and Procedure approved amendments to several of the Federal Rules of Evidence—including Rule 702, which governs the admissibility of expert witness...more

Faegre Drinker Biddle & Reath LLP

Experts’ Disagreement with Medical Literature Leads to Exclusion

Peer-reviewed literature can be a powerful tool in attacking an opposing expert’s opinions. A solid, on-point article can do more than merely satisfy several of the so-called Daubert factors for assessing reliability – by...more

Epstein Becker & Green

One Step Closer to a Revised Standard for the Admissibility of Expert Testimony Under Rule 702

Epstein Becker & Green on

The Judicial Conference of the United States’ Committee on Rules of Practice and Procedure seems poised to advance proposed amendments to Federal Rule of Evidence 702, after the Advisory Committee on Evidence unanimously...more

Faegre Drinker Biddle & Reath LLP

Pathologist Stopped Short of Offering Could-Have, Should-Have Opinions

In personal injury and wrongful death cases, the plaintiff bears the burden of proving medical causation, which almost universally requires testimony from a competent expert.  Some plaintiffs offer testimony from forensic...more

Faegre Drinker Biddle & Reath LLP

It’s not what happened, but why: First Circuit rejects conclusory, unsupported expert opinions

It is not uncommon for an opposing expert to opine that the existence of injury alone implies negligence, nor is it unusual to find that such opinions are supported only by general reliance on “literature” with no discernible...more

Faegre Drinker Biddle & Reath LLP

Third Circuit Confirms That Alleged Defect in “Simple” Component of More Complex System Must Be Proven by Expert Testimony When...

A plaintiff who alleges that a product is defective usually has to offer expert testimony in support of that allegation. This should come as no surprise for complex products – if it took a team of scientists and engineers to...more

Butler Weihmuller Katz Craig LLP

Doctors, Scientists, & Engineers - Oh My! Changes to Federal Rule 702 are Likely Coming

Federal Rule of Evidence 702—Testimony by Expert Witnesses—was promulgated in 1975 when Congress first enacted the Federal Rules of Evidence. Original Rule 702 simply stated that “[i]f scientific, technical, or other...more

Faegre Drinker Biddle & Reath LLP

Eleventh Circuit Affirms Exclusion of Expert Opinion Based on Unjustified Analogy

In the space of a single paragraph, General Electric Co. v. Joiner softened Daubert’s comment that a court’s assessment of expert opinion admissibility should focus “solely on principles and methodology, not on the...more

Freeman Law

Expert Witnesses and the Daubert Standard

Freeman Law on

Expert testimony is often critical to establish a claim or defense. Expert testimony is allowed where scientific, technical, or other specialized knowledge will assist the judge or jury to understand the evidence in a case...more

Faegre Drinker Biddle & Reath LLP

Let Me Google That for You: A Recent Central District of Illinois Opinion Highlights the Limits of Googling by Expert Witnesses...

While we all rely on Google or other internet search engines to find and absorb information quickly these days, a recent decision in the Central District of Illinois highlights the problems for expert witnesses relying on...more

Cozen O'Connor

Requiring an Expert to Have Experience with the Specific Product at Issue is “Too High” a Standard

Cozen O'Connor on

On April 22, 2021, the U.S. Court of Appeals for the 11th Circuit found in Moore v. Intuitive Surgical, Inc., Case No. 1:15-cv-00056-LAG (11th Cir. April 22, 2021), that a surgeon serving as an expert who had not used the...more

Faegre Drinker Biddle & Reath LLP

Eleventh Circuit Holds Expert Qualified in Surgical Tool Suit Despite Lack of Experience Using the Product

The Eleventh Circuit recently reinstated a case alleging a surgical tool caused internal burns during a hysterectomy surgery, holding that the district court erred in disqualifying an expert on the basis that he had never...more

Butler Snow LLP

Solving the Problem of Daubert’s “Shaky but Admissible Evidence”: An Amendment to Federal Rule of Evidence 702 May Be Forthcoming

Butler Snow LLP on

In the face of extraordinary challenges, 2020 has yielded profound developments within the scientific community: from the accelerated development and approval of highly effective and safe vaccines normally years in the making...more

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