Court: United States District Court for the Middle District of Georgia, Valdosta Division
Case Name: Williams v. Tristar Prods.
Citation: 2019 U.S. Dist. LEXIS 144919
The mechanical engineering expert, retained by the plaintiff, opined on the flaws of the pressure cooker. However, the defendant argued the expert couldn’t give such opinions because he was not a human factors or warnings expert. The defendant also claimed the expert didn’t read the plaintiff’s testimony before forming his opinions.
The plaintiff filed a products liability and personal injury claim against the defendant concerning a pressure cooker the defendant manufactured. The pressure cooker exploded while the plaintiff was operating it, causing her to suffer injuries. The plaintiff hired a mechanical engineering expert witness to offer an opinion regarding the cause of the incident. The expert testified that the cooker showed fault when the lid was half open. However, the plaintiff later testified that she was using the cooker with the lid completely closed.
The mechanical engineering expert had extensive experience in developing and designing machines, products, tools, locking and latching devices, and fasteners. The plaintiff retained the expert to use his mechanical engineering expertise. Additionally, the expert was familiar with the defendant’s pressure cooker. As such, the expert could determine whether the accident was due to a defect in the pressure cooker.
The Plaintiff’s Mechanical Engineering Expert
The defendant filed a motion to exclude the views of the mechanical engineering expert on three grounds:
- His observations did not fit the facts of the case
- His opinions were not the results of reliable scientific methodology and therefore would not help the trier of fact
- He was not competent to give such opinions because he was clearly not an expert on human factors or warnings
The expert explained in detail his examination of a prototype pressure cooker. He testified that he was familiar with the pressure cookers made by the defendant. Furthermore, the expert testified that his experience with the pressure cooker was from testifying as an expert in related litigation. The mechanical engineering expert claimed the pressure cooker developed by the defendant was flawed in a number of ways. He opined that the contents could be pressurized despite the fact that the lid wasn’t in a completely locked position. The expert’s views were focused on his study of the topic of the pressure cooker. Additionally, his views were based on extensive testing of the defendant’s pressure cooker models.
Here, the plaintiff had testified that she had completely closed the pressure cooker. The defendant argued that the expert’s views did not fit the facts of the case as required by Daubert. According to the defendant, the expert did not explain how a pressure cooker could fail in a completely locked position. In addition, the defendant argued that the expert’s opinions did not comply with Daubert‘s fit requirement. The expert had not read the plaintiff’s testimony before forming his opinions. The defendant also claimed that the expert did not carry out any tests on the incident cooker.
The mechanical engineering expert had expressed his opinions prior to the plaintiff’s deposition. However, the court noted that, in addition to his extensive knowledge and experience, he based his opinions on the recorded documents, testing an exemplar pressure cooker made by the defendant, and assessment of the incident cooker. This evidence supported his opinions, despite being at odds with parts of the plaintiff’s testimony. The court believed that it was the job of the jury to weigh up competing evidence.
The court also noticed that the expert had knowledge not only of designing products. The expert also had knowledge of drawing up warnings, instructions, and manuals for cockpit door locking systems and pneumatic devices. Furthermore, the mechanical engineering expert did not claim to be an expert on human factors. However, he had studied human factors as part of his engineering education. The court noted that the plaintiff did not intend to present the expert as an authority on human factors. Yet, the court found that he could give evidence as to the views in his study on the misleading information in the owner’s manual.
The court denied the defendant’s motion.
Key Takeaways for Experts
This case illustrates the importance of testing and research in product liability cases. In this case, the expert based his opinions not only on recorded documents but also on testing the defective product. Before coming to a conclusion, you should review all available records and reports as well as test the allegedly defective product to give an accurate and reliable opinion. By doing so, your expert testimony can withstand challenges from the opposing counsel.