Calhoun v. Yamaha Motor Corp.
350 F.3d 316 (2003)
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Rule of Law:
Under Federal Rule of Evidence 702, an expert's opinion testimony is inadmissible if it lacks a reliable foundation supported by specific knowledge, data, or scientific methodology, even if the witness is generally qualified in their field.
Facts:
- In June 1989, twelve-year-old Natalie Calhoun was vacationing with a friend's family at a resort in Puerto Rico.
- The friend's mother, Corinne Fox, gave the girls permission to rent a Yamaha Wave-jammer jet ski, which had a warning recommending a minimum operator age of fourteen.
- A concessionaire, Samuel Roffe, gave Natalie approximately ten minutes of instruction after she falsely stated she was fourteen years old.
- Natalie had never operated a jet ski before; during her ride, she struggled, fell off, and remounted the machine.
- After remounting, Natalie restarted the jet ski, which then accelerated at high speed across a lagoon directly toward an anchored boat.
- Witnesses described Natalie as appearing 'frozen' and 'scared stiff' as she approached the boat, making no attempt to turn.
- Natalie crashed into the boat and died from massive head and neck trauma.
Procedural Posture:
- Natalie Calhoun's parents, Lucien and Robin Calhoun, sued Yamaha Motor Company, Ltd. and Yamaha Motor Corporation, U.S.A. in the United States District Court.
- The Calhouns' complaint asserted claims including strict liability, negligence, and breach of implied warranties.
- Following several appeals that reached the U.S. Supreme Court on other legal matters, the case was returned to the district court for a jury trial.
- At trial, the district court conducted Daubert hearings and ruled to limit the scope of testimony from the Calhouns' three expert witnesses.
- At the close of evidence, the district court granted Yamaha's motion for judgment as a matter of law on the negligence claims but denied it for the strict liability claims.
- The jury rendered a verdict in favor of Yamaha on the remaining strict liability claims.
- The Calhouns, as appellants, appealed the district court's rulings to the U.S. Court of Appeals for the Third Circuit.
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Issue:
Did the district court abuse its discretion under Federal Rule of Evidence 702 by limiting the testimony of plaintiffs' expert witnesses to general matters and excluding specific opinions that lacked a reliable scientific or factual foundation?
Opinions:
Majority - Scirica, Chief Judge
No. The district court did not abuse its discretion because Federal Rule of Evidence 702 requires trial courts to act as 'gatekeepers' ensuring that expert testimony is not only offered by a qualified witness but is also reliable and based on a scientifically valid foundation for the specific opinion being asserted. The court reasoned that while the plaintiffs' experts possessed general qualifications in their respective fields (human factors, marine safety, naval architecture), their specific opinions lacked the necessary reliability. For example, Dr. Karnes's theory that a stress reaction would cause a rider to clench the throttle was speculative and unsupported by literature or testing. Similarly, opinions from all three experts that the minimum age should be sixteen were inadmissible because they could not provide any data or analysis to support that specific age over any other. The court concluded that an expert's general knowledge can support testimony on general matters, but offering specific conclusions requires more specific, reliable support that was absent here.
Analysis:
This case reinforces the trial court's critical 'gatekeeper' role under the Daubert standard and Federal Rule of Evidence 702. It clarifies that an expert's general qualifications are insufficient to render their specific opinions admissible; each opinion must have its own reliable methodological basis. The decision demonstrates that appellate courts will give significant deference to a trial court's detailed analysis of reliability, making it harder to challenge the exclusion of expert testimony on appeal. For future products liability cases, this precedent underscores the need for experts to ground their conclusions about design defects or inadequate warnings in concrete testing, data, or peer-reviewed science, rather than relying solely on experience or subjective belief.
