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Stead v. FE Myers Co., Div. of McNeil Corp.

Citations: 785 F. Supp. 56; 1990 U.S. Dist. LEXIS 19984; 1990 WL 341706Docket: Civ. 89-169

Court: District Court, D. Vermont; November 26, 1990; Federal District Court

Narrative Opinion Summary

In a case before the United States District Court for the District of Vermont, plaintiffs sought damages related to their alleged exposure to oil from a submersible pump manufactured by F.E. Myers Co., including costs for medical monitoring due to an increased risk of cancer. The Steads filed their complaint, asserting claims of negligence, breach of warranty, strict liability, and violations of Vermont's Groundwater Protection Act. Myers filed a motion in limine to exclude expert testimony on the increased cancer risk, arguing that the experts could not quantify the risk with reasonable medical certainty and that the plaintiffs had failed to disclose this aspect of the testimony. The court ruled that the Steads' disclosures had been timely and sufficient to inform Myers, and that the testimony was relevant to the claim for medical monitoring costs, as it demonstrated a substantial risk necessitating future medical actions. The court further held that the probative value of the evidence outweighed any potential prejudice to Myers, resulting in the denial of Myers' motion to exclude the testimony regarding increased cancer risk, thus allowing the evidence to be considered in addressing the plaintiffs' claims.

Legal Issues Addressed

Admissibility of Expert Testimony on Increased Cancer Risk

Application: The court ruled that expert testimony related to an increased cancer risk due to exposure was admissible despite the experts not quantifying the risk with reasonable medical certainty.

Reasoning: Myers' motion was based on two grounds: (1) the plaintiffs' expert witnesses, Dr. G. John DiGregorio and Dr. Robert Rutman, could not quantify the increased cancer risk with reasonable medical certainty.

Disclosure Requirements for Expert Testimony

Application: The court found that the plaintiffs had made timely disclosures about the experts' testimony concerning the need for medical monitoring and potential cancer testing, thus adequately informing the defendant.

Reasoning: The court found that the Steads' disclosures about the need for monitoring, including potential testing for cancer, were timely and had adequately informed Myers.

Probative Value Versus Prejudicial Impact

Application: The court determined that the probative value of the testimony on increased cancer risk outweighed any potential prejudice to the defendant, thus allowing the evidence to be presented.

Reasoning: The court determined that the probative value of this evidence was not outweighed by any potential prejudice to Myers.

Relevance of Evidence to Claim for Future Medical Monitoring Costs

Application: The evidence concerning increased cancer risk was deemed relevant to the plaintiffs' claim for medical monitoring costs, as the risk substantiated the necessity for future medical measures.

Reasoning: Hence, the court deemed the testimony regarding increased cancer risk relevant to the Steads' claim for future medical monitoring costs.