Weisgram v. Marley Co.
Citation and Court
528 U.S. 440 (2000), Supreme Court of the United States
Facts
Weisgram’s family sued Marley Co. for wrongful death, alleging a defective heater caused a fatal fire. The jury returned a verdict for the plaintiffs. The Eighth Circuit found that the plaintiffs’ expert testimony had been improperly admitted under Daubert and Joiner, and that without the expert testimony, there was insufficient evidence to support the verdict. The court then directed judgment as a matter of law for Marley rather than remanding for a new trial.
Issue
Whether an appellate court, after finding that expert testimony was erroneously admitted at trial and that without it the evidence is legally insufficient to support the verdict, may direct entry of judgment as a matter of law for the opposing party rather than remanding for a new trial.
Holding
The Supreme Court unanimously held that an appellate court has the power to direct entry of judgment as a matter of law when the only evidence supporting a jury verdict was improperly admitted expert testimony, without automatically granting a new trial.
Rule / Doctrine
When an appellate court determines that expert testimony admitted at trial was inadmissible under FRE 702/Daubert standards, and that without such testimony the evidence is legally insufficient to support the verdict, the court may direct judgment as a matter of law for the moving party. Parties who rely on expert evidence to establish their case bear the risk that the evidence may be excluded on appeal.
Significance
Weisgram v. Marley Co. is important for the Daubert trilogy because it shows the high stakes of expert testimony admissibility decisions. It also settles an important procedural question about appellate authority after exclusion of expert evidence, reinforcing that parties must ensure their experts will satisfy admissibility standards.