Christophersen v. Allied-Signal and Expert Testimony Rules

Case Background and District Court Ruling

The case of Christophersen v. Allied-Signal revolves around a deceased individual, Albert Roy Christophersen. Mr. Christophersen worked at a Marathon Manufacturing plant producing nickel-cadmium batteries. Over the course of his career, he was repeatedly exposed to fumes from the production process in the course of his duties. When Mr. Christophersen ultimately passed away from cancer, his survivors sued the company. They claimed that the products involved in the battery production were the cause of the cancer that killed him. It was further alleged that the companies were aware of the dangerous nature of the materials used in the production process and failed to protect Mr. Christophersen.

At the district court level, the court ruled that the plaintiffs "failed to state a design defect or manufacturing defect claim" and thus granted the defendant's motion for summary judgment (Appellate court judgment). The court also granted a motion for summary judgment on the marketing defect claim for failing to prove causation. The plaintiffs had made their claim on the basis of expert testimony from a Dr. Miller. The district court ruled that Dr. Miller's opinion should be excluded.

Appellate Court Review of Expert Testimony

The plaintiffs appealed, and the appellate court weighed the issue of Dr. Miller's testimony. The appellate court recognized that it could only overturn the ruling of the district court if the exclusion of Dr. Miller's testimony was "manifestly erroneous." The court turned to the Federal Rules of Evidence to help make its determination. There are four criteria that must be met in order for expert testimony to be admissible. The first three comprise the threshold that all expert testimony must pass; the final criterion is that "the testimony's potential for prejudice not outweigh its probative value" (Appellate court judgment).

The district court had relied on Rule 703, pertaining to the witness's methodology, to exclude Dr. Miller's testimony. Dr. Miller's testimony was in fact based on an interview with a co-worker of Mr. Christophersen. Little other research was conducted by Dr. Miller, and his work was not consistent with the methods normally used by oncologists or pathologists — fields in which he held no specialized standing. The appellate court thereby ruled that the district court was not manifestly erroneous and did not err in granting summary judgment.

Significance of the Ruling for Rule 703

The final holding is significant with respect to expert and scientific testimony for several reasons. First, it upheld the integrity of Rule 703. Had the appellate court overruled the district court, Rule 703 would have lost much of its power to protect against untrustworthy "expert" witnesses. The ruling therefore demands that an expert witness actually provide expert testimony.

Without this ruling, an expert witness could be called to the stand but could base his or her testimony on methodology that was not consistent with expert practice. In this case, Dr. Miller admitted that there were three main models used to test for such causation, yet also admitted that he did not use any of them. The plaintiffs clearly believed that placing an MD on the stand who agreed with their case would be sufficient — perhaps expecting that a jury would be sympathetic if the decision came down to a proverbial "battle of witnesses." However, in this case there was no such battle. Dr. Miller was not a qualified expert, and while his testimony was not excluded on those grounds alone, it could have been. Regardless, his lack of expertise was revealed through his faulty methodology.

Works Cited

Christophersen v. Allied-Signal Corporation. Retrieved April 12, 2009 from http://altlaw.org/v1/cases/518069

Faulk, Richard O. "The Unanswered Questions of Christophersen v. Allied-Signal Corporation." Villanova Environmental Law Journal, vol. 4, no. 1, 1992, pp. 21–39.