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Barbara Head and Ray Head v. Lithonia Corporation, Inc., a Foreign Corporation

Citations: 881 F.2d 941; 105 A.L.R. Fed. 291; 28 Fed. R. Serv. 618; 1989 U.S. App. LEXIS 11478; 1989 WL 87818Docket: 88-2595

Court: Court of Appeals for the Tenth Circuit; August 8, 1989; Federal Appellate Court

Narrative Opinion Summary

In the case concerning products liability, the plaintiffs, Barbara and Ray Head, filed a lawsuit against Lithonia Corporation following Barbara's injury caused by a defective light fixture. The Oklahoma jury initially awarded $100,000 for Barbara's permanent injuries and $100,000 for Ray's loss of consortium. The district court allowed various expert testimonies, including the contentious testimony of Dr. Michael Haugh regarding topographical brain mapping, which was not widely accepted in the neurological community. Lithonia's objections to the foundation of admitted evidence were overruled without explanation. On appeal, the court found the district court's failure to establish the reliability of the medical evidence warranted vacating the judgment and remanding for a new trial. The appellate court emphasized the need for scientific evidence to be demonstrably reliable under Federal Rule of Evidence 703, as previously indicated in the case of Barrel of Fun. Consequently, the court vacated the judgment based on the insufficient foundation for the expert evidence, necessitating a retrial without addressing other claimed errors.

Legal Issues Addressed

Admissibility of Scientific Evidence

Application: The appellate court vacated the judgment because the district court failed to establish a foundation for the reliability of the scientific evidence presented by the plaintiff’s expert.

Reasoning: The appellate court found the first three claims of error unmeritorious, but vacated the judgment and remanded for a new trial due to the district court's failure to establish a proper foundation for the introduction of certain medical testing evidence.

Cross-Examination and Reliability of Expert Methods

Application: The defense successfully challenged the reliability of the plaintiff's expert's methods through cross-examination, highlighting the experimental status and lack of acceptance in the field.

Reasoning: Defense counsel challenged the reliability of topographical brain mapping through cross-examination, highlighting its experimental status and lack of acceptance among neurology experts and the American Academy of Neurology.

Expert Testimony Under Federal Rule of Evidence 703

Application: The court allowed expert testimony based on data that was not widely accepted or proven reliable, leading to the vacating of the judgment due to lack of proper foundation.

Reasoning: Under Rule 703 of the Federal Rules of Evidence, an expert can base opinions on facts or data that are reasonably relied upon by experts in the field, even if those facts are not admissible as evidence.

Products Liability

Application: The plaintiff successfully demonstrated a products liability claim by presenting evidence of a defect in the light fixture's fastener that caused injury.

Reasoning: Barbara Head and Ray Head filed a products liability lawsuit against Lithonia Corporation after Barbara was injured when a reflector from a Lithonia light fixture fell and struck her on the head while she was at work.