Fourth Circuit Finds Abuse Of Discretion In Admitting Expert Testimony, Reversing Multi-Million-Dollar Verdict

• Published date: 17 September 2021
• Subject Matter: Consumer Protection, Product Liability & Safety
• Law Firm: Winston & Strawn LLP
• Author: Mr Christopher B. Essig and Francie N. Berger

The Fourth Circuit recently reversed a decision to admit expert evidence in a products liability matter involving the packaging of garage doors/hoods in Sardis v. Overhead Door Corp. There, without expert evidence, the Court found that the Plaintiff-Appellee could not succeed on any of its claims and, therefore, entered judgment in Defendant-Appellant's favor. 2021 WL 3699753 (4th Cir. Aug. 20, 2021). The case reaffirms the significance of courts making explicit Daubert findings on the record. It also underscores the potential import of making relevance arguments under Daubert, as Defendant was successful in arguing that experts' failures to establish an industry standard or use the applicable standard for a manufacturer's duties under state law made their opinions irrelevant.

In Sardis, Plaintiff was the administrator of the estate of her husband, who died after falling when the handhold for one of Defendant Overhead Door Corporation's ("ODC") packages broke. Id. at *1-2. "Essentially, the Estate alleged that ODC was negligent in designing the Container's handholds, and that this defective design caused [decedent's] injuries."...