Also known as: Trilogy
Written by attorneys · grounded in primary & secondary sources — see below
A series of Supreme Court decisions establishing the standards for admissibility of expert testimony. The decisions confirm that trial courts perform a gatekeeping function by excluding opinions containing too great an analytical gap between the data and the conclusion offered.
Flora Ford sued Frontier Capital after a workplace injury. She offered an engineer who concluded the machine guard was defective based on a brief visual inspection without measurements or simulations. The district court excluded the testimony for an impermissible analytical gap. On appeal the court affirmed under abuse of discretion review because the trial judge properly performed the gatekeeping function.
Paul Price sued a chemical manufacturer after alleged exposure. His expert linked the illness to the product solely by citing general literature without testing exposure levels in the plaintiff. The district court excluded the testimony. The appellate court affirmed because the analytical gap between the literature and the specific causation opinion was too great.
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Dana Drew sued an auto maker after a rollover. Her expert opined the roof was defectively designed after reviewing photos but without crash testing or calculations. The trial court excluded the testimony. On appeal the court upheld the ruling because the judge correctly found an impermissible gap between the limited data and the design-defect conclusion.
Evan Ellis sued a hospital after surgery complications. His physician expert attributed the outcome to negligence based only on the hospital record without differential diagnosis or supporting studies. The district court excluded the opinion. The court of appeals affirmed under abuse-of-discretion review because the analytical gap rendered the testimony unreliable.
The trilogy consists of Daubert, Kumho Tire, and Joiner. Joiner clarified that appellate courts review a district court's exclusion of expert testimony for abuse of discretion and that an expert opinion may be excluded when there is too great an analytical gap between the data and the conclusion.
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Joiner confirms that trial courts must screen both the relevance and reliability of expert testimony. A court may exclude an opinion when the expert's conclusions are not supported by sufficient facts or reliable methodology.
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Appellate courts review a district court's decision to admit or exclude expert testimony under Daubert for abuse of discretion. The trial judge's gatekeeping determination is given substantial deference.
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A court may conclude there is simply too great an analytical gap between the data and the opinion proffered. Exclusion is proper where the expert's conclusions are not supported by sufficient facts or reliable methodology.
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…as enunciated by this Court in Textile Workers Union v. Lincoln Mills , 353 U. S. 448 (1957), and the Steelworkers trilogy.[^maj-6] See also Boys Markets v. Retail Clerks Union , 398 U. S. 235 (1970); Gateway Coal Co. v. United Mine Workers of America , 414 U. S. 368 (1974). We disagree. III Title…