News & Analysis as of

Causation Expert Testimony Admissibility

Faegre Drinker Biddle & Reath LLP

Foundation, Not Façade — The Fifth Circuit Affirms the Proper Basis Requirement for Admissibility of Expert Opinions in Newsome v....

In a toxic tort case, plaintiffs must establish general causation. If a substance is incapable of causing the type of injury plaintiff claims, then it certainly didn’t cause theirs. Under Texas law, toxic tort plaintiffs must...more

Faegre Drinker Biddle & Reath LLP

To Depose or Not to Depose: When Challenging Opposing Nonretained Experts Becomes Challenging

Federal Rule of Civil Procedure 26(a)(2) requires parties to disclose the opinions of experts who may present evidence at trial. If the disclosures are inadequate, Rule 37(c) requires exclusion of the opinions “unless the...more

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

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

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

Goldberg Segalla

Defendants Successful on Motion to Strike Plaintiff’s Expert’s Specific Causation Opinion

Goldberg Segalla on

United States District Court for the Northern District of California, July 11, 2022 Plaintiff, Frank Shelton, filed an asbestos-related lawsuit alleging his exposure to asbestos from various defendants’ products while he...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

Plaintiff Shoots an Airball Against Nike in Design Defect Case

ase In the wake of March Madness, it is only appropriate to call attention to an opinion laced with pithy basketball puns. In Nachimovsky v. Nike, Inc. et al., 2022 WL 943421 (E.D.N.Y. Mar. 29, 2022), Plaintiff injured his...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

Faegre Drinker Biddle & Reath LLP

Growing Pains: The Story Behind Florida’s Daubert Arc – Part 2

The Aftermath of Marsh - When the Marsh case was decided in 2007 its broad interpretation of the “pure opinion exception” and narrow vision of the role of Frye took Florida expert evidence admissibility law well out of the...more

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