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Stasior v. National Railroad Passenger Corp.

Citations: 19 F. Supp. 2d 835; 50 Fed. R. Serv. 858; 1998 U.S. Dist. LEXIS 13766; 1998 WL 565922Docket: 95 C 1958

Court: District Court, N.D. Illinois; August 28, 1998; Federal District Court

Narrative Opinion Summary

The case involves a lawsuit filed by a former reservation sales agent against the National Railroad Passenger Corporation (Amtrak) under the Federal Employers Liability Act (FELA). The plaintiff alleged that Amtrak's negligence caused her carpal tunnel syndrome (CTS) and related injuries. She sought damages exceeding $50,000. Central to the case were expert testimonies from Dr. Gary Herrin and Dr. Michael Shinnick, who argued that workplace conditions contributed to the plaintiff's injuries. However, Amtrak contested their testimony under Rule 702 and the Daubert standard. The court found the expert opinions inadmissible due to a lack of scientific rigor and failure to demonstrate a causal link between the plaintiff's work conditions and her injuries. Without admissible expert testimony, the plaintiff could not establish the necessary elements of negligence under FELA, leading the court to grant Amtrak's motion for summary judgment. The court also ruled on procedural motions, excluding expert testimonies and denying a statute of limitations defense raised by Amtrak earlier in the proceedings. Ultimately, the plaintiff's failure to present a genuine issue for trial resulted in a decision in favor of Amtrak.

Legal Issues Addressed

Admissibility of Expert Testimony under Daubert Standard

Application: The court excluded the testimonies of Dr. Herrin and Dr. Shinnick because they did not meet the reliability criteria of the Daubert standard.

Reasoning: Amtrak is seeking to exclude the expert testimonies of Gary Herrin and Michael Shinnick under Rule 702 of the Federal Rules of Evidence and Daubert standards, and it requests summary judgment based on the argument that Stasior has not provided admissible evidence to support her FELA claim.

Burden of Proof under FELA

Application: The plaintiff's burden is lower under FELA, but the failure to provide admissible expert evidence led to dismissal.

Reasoning: The Seventh Circuit has established that the evidence burden for FELA liability is lower than in typical negligence cases; the plaintiff only needs to show that the employer's negligence contributed, even minimally, to the injury.

Expert Testimony Qualifications under Rule 702

Application: Dr. Herrin was deemed qualified to discuss occupational risk factors but his testimony was found unreliable due to lack of scientific backing.

Reasoning: The court found that Dr. Herin, despite lacking medical training, is qualified to testify on the relationship between occupational factors and carpal tunnel syndrome (CTS) due to his expertise in ergonomics.

Federal Employers Liability Act (FELA) Liability

Application: The claim was dismissed because the plaintiff failed to provide admissible evidence under FELA standards showing employer negligence contributed to her injuries.

Reasoning: Stasior's negligence claim against Amtrak is based on the Federal Employers' Liability Act (FELA), which holds railroad companies accountable for employee injuries caused by negligence.

Summary Judgment Standards

Application: The court granted summary judgment to Amtrak as Stasior failed to raise a genuine issue of material fact due to inadmissible expert evidence.

Reasoning: The court will grant summary judgment only if there are no genuine issues of material fact and the moving party is entitled to judgment as a matter of law.