General Electric Co. v. Joiner

Brief Fact Summary. Joiner (Plaintiff) was exposed to PCBs and diagnosed with cancer. PCBs are dangerous to human health. Plaintiff sued General Electric Co. (Defendant) for “promoting” his cancer.

Synopsis of Rule of Law. Abuse of discretion is the proper standard of review of a district court’s evidentiary ruling, i.e. did the district court abuse its discretion in granting Defendant’s Motion for Summary Judgment?

Facts. Plaintiff has worked as an electrician since 1973. This required Plaintiff to work around transformers, and the dielectric fluid used as a coolant got into his eyes and mouth, and stuck to his arms and hands. In 1983, the city discovered that the fluid in some of its transformers contained PCBs, which are hazardous to the health of humans. In 1991, Plaintiff was diagnosed with small cell lung cancer. He sued Defendant because they manufactured transformer and dielectric fluid. Plaintiff had been a smoker for eight years and there was a history of lung cancer in his family. Plaintiff alleged that his exposure to PCBs “promoted” his cancer; had it not been for his exposure to these substances, his cancer would not have developed for many years, if at all. Defendant removed the case to federal court and then moved for summary judgment. Defendant claimed there was no evidence that Plaintiff suffered significant exposure to PCBs and that there was no admissible scientific evidence
that PCBs promoted Plaintiff’s cancer. The district court ruled that there was a genuine issue of material fact, but there was no evidence that Plaintiff had been exposed to PCBs, and the testimony of Plaintiff’s experts failed to show that there was a link between exposure to PCB and small cell cancer. The case was dismissed. The court of appeals reversed. The Supreme Court of the United States granted certiorari.

Issue. Was Plaintiff’s case properly dismissed on Defendant’s Motion for Summary judgment?

Held. Yes. Judgment reversed. The district court’s ruling was affirmed.
* Abuse of discretion is the proper standard of review of a district court’s evidentiary ruling; did the district court abuse its discretion in granting Defendant’s motion for summary judgment? Under the Federal Rules of Evidence and the Frye case, the trial judge is the “gatekeeper” in screening evidence. In this case, the district court did not abuse its discretion.
* The animal studies upon which Plaintiff relied did not support his contention that exposure to PCBs had contributed to his cancer. No study demonstrated that adult mice developed cancer after being exposed to PCBs. One of the experts admitted that no study had demonstrated that PCBs led to cancer in any other species. The studies were so dissimilar to the facts presented in this litigation that is was not an abuse of discretion for the district court to have rejected Plaintiff’s reliance on them.
* A court may conclude that there is simply too great an analytical gap between the data and the opinions proffered.
Concurrence. (Justice Breyer) The trial judge is the gatekeeper of evidence, however, judges are not scientists and should be strongly encouraged to utilize their inherent authority to appoint experts.
* (Justice Stevens), concurring in part and dissenting in part. The court of appeals expressly decided that a “weight of the evidence” approach was scientifically acceptable. That opinion is persuasive. The Environmental Protection Agency (EPA) uses the same type of evidence as the Plaintiff. The evidence as a whole raises an inference that PCBs promote lung cancer. The court has not held that it would have been an abuse of discretion to admit the expert testimony.

Discussion. Here, the Justices agree that the trial judge is to be the gatekeeper of evidence. The majority opinion states that the District court did not abuse its discretion in granting the summary judgment motion. The majority feels confident that the trial court was capable of determining or dismissing the causal connection between Plaintiff’s claim and the evidence provided.