Kumho Tire Co. v. Carmichael
Citation: 526 U.S. 137 (U.S. Supreme Court, 1999)
Facts
A minivan tire manufactured by Kumho Tire blew out, causing an accident that killed one passenger and injured others. The plaintiffs retained a tire failure analyst who testified that the blowout was caused by a manufacturing defect rather than owner abuse. The analyst relied on visual and tactile inspection using criteria he had developed from experience. The district court found the methodology unreliable under Daubert and excluded the testimony, then granted summary judgment.
Issue
Whether the Daubert gatekeeping obligation applies only to scientific expert testimony, or also to testimony based on technical or other specialized knowledge under FRE 702.
Holding
The Supreme Court held that Daubert’s gatekeeping obligation applies to all expert testimony under FRE 702, not just scientific testimony. The specific Daubert factors may or may not be applicable depending on the nature of the expertise, but the reliability inquiry is always required.
Rule
Trial courts must ensure the reliability and relevance of all expert testimony — scientific, technical, and based on other specialized knowledge. The Daubert factors are illustrative, not exhaustive, and the trial court has broad discretion in determining how to evaluate reliability for any given type of expertise. The goal is to ensure the expert’s knowledge “fits” the case and rests on a reliable foundation.
Significance
Kumho Tire extended Daubert beyond science to all forms of expert testimony, completing the framework now codified in FRE 702. It confirmed that experience-based expertise is subject to reliability scrutiny, and it affirmed trial courts’ broad discretion in applying the gatekeeping function.