Thursday, April 01, 2004

11th Circuit Upholds Biomechanical and Accident Reconstruction Testimony

In a products liability action involving an automotive child restraint system, the Eleventh Circuit has upheld the trial court's decision rejecting plaintiffs' objections to defendants' experts on biomechanics and accident reconstruction. Plaintiffs complained that the lower court's opinion did not outline its entire Daubert analysis. But there is no authority, the panel said, to support the contention that district court rulings on Daubert objections must present a comprehensive analysis. Moreover, in denying plaintiffs' motion in limine, the district court expressly adopted defendants' reasoning, which did reflect a comprehensive Daubert analysis, according to the panel. See Edic v. Century Prods. Co., No. 03-10486 (11th Cir. Mar. 31, 2004) (Edmondson, Birch, & Farris, JJ.).

posted by pn at 10:58 AM  

Fed. R. Evid. 702: If scientific, technical, or other specialized knowledge will assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education, may testify thereto in the form of an opinion or otherwise, if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case.