Kumho Tire Company, Ltd. v. Carmichael

Supreme Court of the United States · 1999 · Evidence

EvidenceExpert testimonyRule 702DaubertReliabilityRule 702Daubertexpert testimony

Facts

A minivan's right rear tire blew out, causing a fatal accident, and the Carmichaels sued Kumho Tire claiming the tire was defective. Their expert, Dennis Carlson, a tire failure analyst, concluded from a visual and tactile inspection that a manufacturing or design defect caused the tire tread separation because the tire did not show at least two of four signs of overdeflection abuse. The tire, however, was old, worn, had been inadequately repaired after punctures, and showed some indications that Carlson himself associated with abuse. The District Court found Carlson qualified but concluded that his methodology for analyzing the inspection data and linking it to defect causation was unreliable.

Issue

Does Daubert's Rule 702 gatekeeping obligation apply only to scientific expert testimony, or also to technical and other specialized expert testimony such as engineering testimony? If it does apply, may a trial court use Daubert's specific reliability factors flexibly in evaluating such testimony, and did the District Court act within its discretion in excluding Carlson's testimony here?

Rule

Federal Rule of Evidence 702 imposes a gatekeeping obligation on trial judges to ensure that all expert testimony—scientific, technical, or otherwise specialized—is both relevant and reliable. The specific Daubert factors may be considered when they are reasonable measures of reliability in the particular case, but they are not a mandatory or exclusive checklist, and trial courts have broad latitude both in deciding how to assess reliability and in making the ultimate reliability determination; appellate review is for abuse of discretion.

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

In a products-liability trial in Denver, Nora Velez offers Owen Marks, a bicycle-frame mechanic with 25 years of shop experience, to testify that a cracked mountain-bike fork must have contained a factory defect. Owen based his opinion on a hands-on inspection and his experience, not on laboratory testing. The manufacturer moves to exclude the testimony, arguing that Rule 702 reliability screening applies even though Owen is not a scientist.

How should the trial judge rule on the objection to the court's authority to screen the testimony for reliability?

Explanation. Rule 702 imposes a gatekeeping obligation for all expert testimony covered by the Rule—scientific, technical, and other specialized knowledge. The majority rejected any distinction that would limit reliability screening to purely scientific testimony. A mechanic relying on experience-based technical knowledge is therefore still subject to judicial scrutiny for relevance and reliability. (Derived from Kumho Tire Company, Ltd. v. Carmichael (1999).)