User:Saaalwz/New sandbox

Background

Patrick Carmichael was driving his minivan on July 6, 1993, when the right rear tire blew out. One of the passengers in the vehicle died, and others were severely injured. Three months later, the Carmichaels sued the manufacturer of the tire, claiming that the tire was defective and the defect caused the accident. The Carmichaels' case rested largely on testimony from a tire failure expert.

The tire failure expert relied on features of tire technology that the manufacturer did not dispute, as well as background facts about the particular tire on the Carmichaels' van. The expert's conclusion that a defect in the tire caused the accident rested on certain observations about the tire that Kumho Tire vigorously disputed. Kumho also disagreed with certain aspects of the tire expert's methodology, and asked the federal district court hearing the case to exclude it under Rule 702 of the Federal Rules of Evidence.

The district court took its cue from Daubert v. Merrell Dow Pharmaceuticals, which had solidified a gatekeeping role for trial judges in admitting expert testimony. Under Daubert, certain factors contribute to the reliability, and hence the admissibility, of expert testimony, one of which is the general validity of the expert's methods. The district court found the tire expert's methods not to be scientifically valid, and hence excluded his testimony. This resulted in a conclusion that Kumho Tire would prevail. The Carmichaels appealed to the Eleventh Circuit.

The Eleventh Circuit reversed the district court's ruling. It reasoned that Daubert was expressly limited only to scientific expert testimony and did not apply to "skill- or experience-based observation." The tire expert's testimony rested on such unscientific "observation and experience", and so the Eleventh Circuit reasoned the district court should have made a different ruling based on their legal reasoning over Rule 702 without the Daubert gloss. Kumho Tire asked the Supreme Court to review whether Daubert applied solely to scientific evidence.

Majority opinion

The Court found in the text of Rule 702, a codification of Daubert, a gatekeeping function for federal trial judges who had to determine whether expert scientific testimony was admissible in a federal trial. But Rule 702 applies to "scientific, technical, or other specialized knowledge." "This language makes no relevant distinction between 'scientific' knowledge and 'technical' or 'other specialized' knowledge." True, Daubert dealt only with scientific knowledge, but that was the nature of the case, and it did not stray beyond the facts of that case.

The Court observed that the line between "scientific" and "technical" knowledge is not always clear. "Pure scientific theory itself may depend for its development upon observation and properly engineered machinery. And conceptual efforts to distinguish the two are unlikely to produce clear legal lines capable of application in particular cases." If the line between "scientific" and "technical" knowledge was not clear, then it would be difficult for federal trial judges to determine when they were to perform Daubert's gatekeeping function and when to apply some other threshold test the Court might craft for applying Rule 702. Furthermore, the Court saw no "convincing need" to draw a distinction between "scientific" and "technical" knowledge, because both kinds of knowledge would typically be outside the grasp of the average juror. Accordingly, the Court held that the gatekeeping function described in Daubert applied to all expert testimony proffered under Rule 702.

Daubert had mentioned four factors that district courts could take into account in making the gatekeeping assessment—whether a theory has been tested, whether an idea has been subjected to scientific peer review or published in scientific journals, the rate of error involved in the technique, and even general acceptance, in the right case. In the context of other kinds of expert knowledge, the Court conceded, other factors might be relevant, and so it allowed district judges to take other factors into account when performing the gatekeeping function contemplated by Daubert. These additional factors would, of course, depend on the particular kind of expert testimony involved in a particular case. Equally as important, because federal appeals courts review the evidentiary rulings of district courts for abuse of discretion, the Court reiterated that district courts have a certain latitude to determine how they will assess the reliability of expert testimony as a subsidiary component of the decision to admit the evidence at all.

Applying that standard to the evidence proffered by the Carmichaels' tire expert, the Court concluded that the district court correctly refused to admit the expert's testimony. The district court had to determine whether the tire expert's methods could reliably determine what had caused the tire on the Carmichaels' van to explode. The expert's experience as a tire engineer wasn't the problem—the expert had worked for ten years at Michelin. The fact that visual inspection of tires was generally a reliable method wasn't an issue either, because the issue before the court was specific to the tire on the Carmichaels' van. But the expert said that his inspection of the tire led to the conclusion that a defect caused the tire to explode because he did not see evidence of other causes. "Nothing in either Daubert or the Federal Rules of Evidence requires a district court to admit opinion evidence that is connected to existing data only by the ipse dixit of the expert [i.e., only by the statement of the expert himself]." The district court acted within its discretion to exclude the evidence proffered by the tire expert in light of these concerns. Accordingly, the Supreme Court reversed the Eleventh Circuit's decision to overrule the district court.

Kumho Tire Co. v. Carmichael gives a factual framing of the events of the case. As written in the Wikipedia article, the case was fundamental in questioning the use of the Daubert Standard on-scientists that were expert witnesses. Interestingly, the case questions the scientific composition of the manufacturing of a tire, yet it rested on a tire failure expert's testimony. First, Patrick Carmichael got in an accident on his minivan due to the blowing of a tire on the right rear. Therefore, Carmichael, the driver, sued the car company in the next three months for damages caused by the accident, which was blamed on the tire failure caused by defective manufacturing. Noteworthy, the rebuttal that was put forth by Kumho tires was based on the Daubert v. Merrell Dow Pharmaceuticals that redefined the application of the Federal Rule Evidence 702. In the contextual analysis of the Wikipedia article, there are notable loopholes that can be explained through the use of other literary works that are v based on the intricate facets of the case.

First, the Legal Information Institute can help additional details for the article when it fails to expand on the case that acted as a pivotal reference point and the related legal statutes. The mainframe of the article records the major facts when it comes to the case. According to the outlined case files, there was the use of the Daubert v. Merrell Dow Pharmaceuticals as a pivotal reference point for the defense. Referencing to Daubert, there are “four factors–testing, peer review, error rates, and “acceptability” in the relevant scientific community–which might prove helpful in determining the reliability of a particular scientific theory or technique” (Legal Information Institute). The previous ruling was expected to rule out the expert witness statement that was given by Carlson. Grounds for the dismissal were a lack of fulfilling of the precedents that impose a trial judge's special obligation to validate the scientific testimony as being reliable (Legal Information Institute). When the witness took the stand as an expert in tires, there was the affirmation that his qualification was under the Federal Rules of Evidence 702. Carlson's testimony was to be ruled out of the court as the opinion was inefficient in assisting the trier fact. The debate summarized the need for the application of the ‘gatekeeping’ role that the judge holds in cases that are primarily based on scientific testimony. As a result, the page illuminates the blurred lines in the differentiation of technical, scientific, and other specialized forms of testimonies. The credibility of the source comes from its direct correlation with the facts that were represented in court.

Besides, the further elaborations of these aspects show that there are four factors of testing paramount to acceptance of the non-scientific witness statement. As aforementioned, these include; acceptability in the relevant scientific field, peer review, factors-testing, and peer review. Heidi K. Brown further explains these factors in the article, Applying Daubert to Flaubert: Standards for Admissibility of Testimony of Writing Experts. The standards of admissibility of experts are what was put on trial in this case because science and its related concepts are so often put on the trial, meaning that there has to be a criterion upon which such witnesses’ credibility. Brown notes, “Experts routinely play a vital role in the resolution of legal disputes involving a wide range of subject matter, from "hard science" topics like blood-spatter analysis,2 to "soft science" matters such as damages quantification”(145). On the other hand, the author draws to various cases that introduce the controlling, existence, and maintenance of standards used in the acceptance of witness statements. For instance, in Frye v. the United States, there is the explanation that expert opinion is based on a scientific technique that is only admissible on general acceptance and reliable in the given scientific community (Brown). This left the doubt in the meaning of general acceptability that was later resolved by the Federal Rules of Evidence. It then fell upon the Daubert standards to assist in the formation of a threshold consideration for opinion testimony.

Besides, these new standards apply to the various fields of law and science. Subsequently, the case's significant impact was the primary development of an approach that is to be taken in the evaluation of admissibility of expert witness testimony (Ledford). Ledford uses the article, The Implications of Kumho Tire: Applying Daubert Analysis to Warning-Label Testimony in Products Liability Cases, to explain the new changes introduced by the contextual loci in this paper. That is the standards governing expert witness testimony's admissibility similarly applied and revamped in the Kumho Tire Co. v. Carmichael. As aforementioned, there is already the Frye v. the United States and the Daubert v. Merrell Dow Pharmaceuticals Inc., which were revolutionary in the setting out of the basic definition of admissible witness opinions. Subsequently, Ledford finds credibility in the use of credible and reliable sources because they are a reflectance of the accuracy of the reverberating effects of history. Hence, the author seeks to demonstrate the analysis and accompanying problems that apply to potential expert witness testimonies. Their effectiveness is leveled against the warning labels that are put in the products contested in liability cases. Thus, the Wikipedia article has to include details used in user manuals that prompted the court case's admissibility.