General Electric Co. v. Joiner

Supreme Court of the United States · 1997 · Evidence

522 U.S. 136 (1997)

Updated August 1, 2026

Evidenceexpert testimonyabuse of discretionDaubertRule 702scientific evidencegatekeeperipse dixit

Facts

Robert Joiner worked as an electrician around transformers containing mineral-oil-based dielectric fluid, and he often had contact with the fluid. After some transformers were found contaminated with PCB's, Joiner later developed small-cell lung cancer and alleged that exposure to PCB's and their derivatives promoted his cancer. To oppose summary judgment, he offered expert testimony stating that PCB's, furans, and dioxins likely caused or significantly contributed to his cancer. The district court found a factual dispute about PCB exposure but excluded the expert causation testimony as unsupported and granted summary judgment.

Issue

What standard of review should an appellate court apply when reviewing a district court's decision to admit or exclude expert scientific testimony under Daubert? Under that standard, did the district court abuse its discretion by excluding Joiner's experts' testimony linking PCB exposure to his cancer?

Rule

A district court's decision to admit or exclude expert testimony, including scientific testimony under Daubert, is reviewed for abuse of discretion. In performing its gatekeeping role, a district court may exclude opinion testimony when the expert's conclusion is connected to the existing data only by the expert's ipse dixit, or when there is too great an analytical gap between the data and the opinion proffered.

🔒

See the holding & full analysis

Create a free KwikCourt account to unlock the rest of this brief — and practice the case.

The court's holding and reasoning
Doctrine tests, pitfalls & exam hypotheticals
10 practice questions + 4 AI-graded essays on this case

Free sample · practice this case

Test yourself

One of 10 multiple-choice questions for this case. Pick an answer to see why.

In a federal products-liability case in Phoenix, Elena Cruz offers a toxicology expert to prove that vapors from an industrial sealant caused her neurological disorder. The district judge excludes the testimony under Rule 702 and then grants summary judgment because Cruz has no other causation evidence.

On appeal, Cruz argues that because the exclusion effectively ended the case, the court of appeals should review the ruling more stringently than ordinary evidentiary decisions. Which is the best response?

Explanation. The governing rule is that a district court's decision to admit or exclude expert testimony under Rule 702 is reviewed for abuse of discretion. The majority specifically rejected the idea that a more searching appellate standard applies merely because the exclusion is outcome determinative or leads to summary judgment.