General Electric Co. v. Joiner

Brief Fact Summary.

Plaintiff is an electrician who was exposed to dangerous and banned substances called PCBs while on the job. He developed lung cancer that might have been linked to the exposure to PCBs, but he was also predisposed to developing lung cancer due to family history and lifestyle.

Synopsis of Rule of Law.

The appropriate standard for determining whether a trial court erred in excluding expert testimony is abuse of discretion.

Facts.

Plaintiff worked as an electrician for the city of Thomasville, Georgia. His job required him to work with the city’s electrical transformers, which used a mineral-based dielectric fluid as a coolant. The plaintiff often had to stick his hands and arms into the fluid to make repairs, and that fluid would sometimes splash into his eyes and mouth. In 1983, the city discovered that the fluid in some of the transformers was contaminated with polychlorinated biphenyls (PCBs), which are generally considered to be harmful to human health—Congress had banned the production and sale of PCBs in 1978. The plaintiff was diagnosed with small cell lung cancer in 1991. He had been a smoker for eight years, and there was a history of lung cancer in his family.

Issue.

Did the District Court err in determining the plaintiff’s expert testimony to be inadmissible?

Held.

No. The District Court in this case did not abuse its discretion when it excluded the plaintiff’s expert testimony. The 11th Circuit judgement is reversed.

Dissent.

Justice Stevens

Justice Stevens believes that it is not inherently unscientific for experienced professionals to arrive at a conclusion by weighing the scientific evidence. Daubert was concerned with a certain type of “junk science” not at issue here. That being said, the Court did not rule that it would have been an abuse of discretion to admit the testimony—just that it was not an abuse of discretion to not admit the evidence. Thus, Justice Stevens is concurring in part with the decision of the Court.

Concurrence.

Justice Breyer

Justice Breyer believes the Daubert standard of gatekeeping to be of particular importance in the modern age where potentially harmful chemicals are a part of daily life.

Discussion.

The Court expands on the standard for admitting relevant and reliable scientific evidence established under Daubert v. Merrell Dow Pharmaceuticals, which allowed trial court judges to act as gatekeepers in screening the appropriateness of scientific evidence in a given case. The Court also determines that admissibility of testimony is not a disputed issue of fact, and so is reviewable under the abuse of discretion standard. The plaintiff’s expert testimony used animal studies to show the link to lung cancer, but those animal studies measured much higher rates of exposure to PCBs, and no studies showed that adult mice developed cancer after exposure. The facts of the studies were so dissimilar from the plaintiff’s case that the District Court did not abuse its discretion in choosing to exclude the expert testimony.