General Electric Co. v. Joiner
Citation and Court
522 U.S. 136 (1997), Supreme Court of the United States
Facts
Joiner, an electrician with lung cancer, sued General Electric alleging that workplace exposure to PCBs and their derivatives caused his cancer. He offered expert testimony that the exposure caused his cancer. The district court excluded the expert testimony under Daubert as unreliable because the experts’ conclusions were not adequately supported by the studies they cited, and then granted summary judgment for GE.
Issue
What standard of review applies when an appellate court reviews a district court’s decision to admit or exclude expert testimony under Daubert?
Holding
The Supreme Court held that abuse of discretion is the proper standard for appellate review of a trial court’s Daubert ruling on expert testimony, and affirmed the exclusion of Joiner’s experts.
Rule / Doctrine
A trial court’s decision to admit or exclude expert testimony under FRE 702 and Daubert is reviewed for abuse of discretion, not de novo. The trial court acts as a gatekeeper and has broad discretion to exclude expert testimony that is not sufficiently tied to the facts of the case or does not flow from the expert’s methodology. A court may exclude expert testimony when there is too great an analytical gap between the data and the expert’s conclusion.
Significance
Joiner is the second case in the Daubert trilogy (with Daubert and Kumho Tire) and establishes the abuse of discretion standard of review for expert testimony rulings. It also makes clear that trial courts may scrutinize not just methodology but also the connection between the data and the expert’s conclusions.