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Kumho Tire Co. v. Carmichael

Facts of the Case

Provided by Oyez

In 1993, the right rear tire of a minivan driven by Patrick Carmichael blew out and the vehicle overturned. One passenger died in the accident and several others were severely injured. Subsequently, the Carmichaels brought a diversity suit against the Kumho Tire Company and others, claiming that the tire was defective. A significant part of the Carmichaels' case turned on the testimony of Dennis Carlson, Jr., an expert in tire failure analysis. Carlson intended to testify to support the Carmichaels' conclusion that a defect in the tire's manufacture or design caused the blow out. To support this conclusion, Carlson used a methodology that was partly disputed. Kumho moved to exclude Carlson's testimony on the ground that his methodology failed to satisfy Federal Rule of Evidence 702, which provides: "If scientific, technical, or other specialized knowledge will assist the trier of fact..., a witness qualified as an expert...may testify thereto in the form of an opinion." The Federal District Court granted the motion, excluded Carlson's testimony, and entered summary judgment for Kumho. The court found that Carlson's methodology was insufficiently reliable. In reversing, the Court of Appeals concluded that a federal trial judge's "gatekeeping" obligations under the Federal Rules of Evidence were limited to scientific context, and not Carlson's testimony, which the court characterized as skill-or experience-based.

Questions

  1. Does a federal trial judge's "gatekeeping" obligation, under the Federal Rules of Evidence, apply to testimony based on skill or experience as it does to testimony based on scientific knowledge?

Conclusions

  1. Yes. In an opinion delivered by Justice Stephen G. Breyer, the Court held that a federal trial judge's "gatekeeping" obligation applies not only to "scientific" testimony, but to all expert testimony. Justice Breyer wrote for the Court that Federal Rule of Evidence 702 "makes no relevant distinction between 'scientific' knowledge and 'technical' or 'other specialized knowledge. It makes clear that any such knowledge might become the subject of expert testimony." The Court concluded that this interpretation of Rule 702 would insure that an expert witness's testimony rests on a reliable foundation and is relevant to the task at hand. The Court also concluded that the District Court's determination that Carlson's methodology was not reliable was within the court's discretion.