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Federal Rule of Evidence – Expert Testimony Admissability

7th Circuit Court of Appeals

Case Name: Adelaida Anderson v. Raymond Corporation

Case No.: 22-1872

Officials: Easterbrook, Hamilton, and Kirsch, Circuit Judges.

Focus: Federal Rule of Evidence – Expert Testimony Admissability

Anderson worked as a standup forklift operator at a FedEx warehouse in Effingham, Illinois. While pulling a load in July 2017, she hit a bump and fell out of the forklift onto the floor. The forklift continued moving and ran over her leg; the resulting injuries necessitated its amputation.

Anderson brought this diversity suit against the forklift’s manufacturer, The Raymond Corporation, alleging that the forklift was negligently designed. As trial neared, the parties filed dueling motions over the admissibility of the testimony of Dr. John Meyer, one of Anderson’s experts. Meyer believed that Raymond could have made a number of changes to its design that would have prevented Anderson’s accident. Meyer’s primary suggestion was that Raymond equip each of its forklifts with a door to enclose the operating compartment, which would prevent operators like Anderson from falling into the forklift’s path. Like other standup forklift manufacturers, Raymond offers doors as an option that some customers choose, but Raymond does not fit doors to its forklifts as standard. Raymond says it resists fitting doors as standard because a door could impede the operator’s ability to make a quick exit in the event the forklift runs off a loading dock or begins to tip over. The district court concluded that Meyer’s opinion about the absence of a door was inadmissible because it did not satisfy Federal Rule of Evidence 702 or the test set forth in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993). (The district court admitted Meyer’s opinions on other potential design improvements, which are not at issue. According to the Seventh Circuit, the exclusion of Meyer’s opinion was substantially prejudicial to Anderson’s case. Meyer has a “full range of practical experience,” academic, and technical training and his methodology rested on accepted scientific principles, Raymond’s critiques go to the weight his opinion should be given rather than its admissibility.

Reversed, Vacated and Remanded.

Decided 02/01/23

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