Davidov v. Louisville Ladder Group, L.L.C.
Docket: No. 05-1667-CV
Court: Court of Appeals for the Second Circuit; March 9, 2006; Federal Appellate Court
The judgment of the district court is affirmed in this product liability case involving a plaintiff's fall from a ladder manufactured by the defendant. The district court had previously excluded the testimony of the plaintiff's expert on the grounds that the expert's conclusions were in conflict with uncontradicted evidence. This decision was made under an abuse of discretion standard, which allows for exclusion if the expert's opinion lacks a reliable basis in the facts of the case, as outlined in Federal Rule of Evidence 702. The district court found that the expert's theory of causation required several predicate facts to be established, including the force applied by the plaintiff while climbing the ladder and the relative positioning of the ladder's legs. The plaintiff failed to provide evidence supporting these necessary facts, leading the district court to determine that the expert's opinion was speculative rather than grounded in reliable scientific analysis. The plaintiff did not contest the summary judgment apart from asserting that the expert's testimony should have been admissible. Consequently, the court affirmed the district court's judgment.