Adams v. Little Giant Ladder Systems, LLC

District Court, S.D. West Virginia·Decided November 13, 2024·No. 3:22-cv-00460·Unknown

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE SOUTHERN DISTRICT OF WEST VIRGINIA

HUNTINGTON DIVISION

JASON ADAMS and DONETTA ADAMS, his wife,

Plaintiffs,

v. CIVIL ACTION NO. 3:22-0460

LITTLE GIANT LADDER SYSTEMS, LLC, a Utah Limited Liability Company,

Defendant.

MEMORANDUM OPINION & ORDER Pending are Defendant Little Giant Ladder Systems, LLC’s Motion to Exclude the Expert Testimony of David Kassekert, P.E. (Def.’s Mot.), ECF No. 72, and Plaintiffs’ Renewed Motion to Exclude the Opinions and Testimony of Dr. Ellen Wright (Pl.’s Mot.), ECF No. 77.1 For the reasons that follow, the Court GRANTS the Defendant’s Motion and DENIES the Plaintiffs’ Motion. BACKGROUND This is a products liability case involving an articulating (i.e., multi-position) ladder

1 The Court heard oral argument on these Motions on October 28, 2024. ECF No. 96. The Court also considered Defendant’s Memorandum in Support of Defendant Little Giant Ladder Systems, LLC’s Motion to Exclude the Expert Testimony of David Kassekert, P.E. (Def’s Mem.), ECF No. 73; Plaintiffs’ Memorandum of Law in Support of Plaintiffs’ Renewed Motion to Exclude the Opinions and Testimony of Dr. Ellen Wright (Pl.’s Mem.), ECF No. 78; Plaintiffs’ Memorandum Response to Defendant’s Motion to Exclude the Expert Testimony of David Kassekert, P.E. (Pl.’s Resp.), ECF No. 81; Defendant’s Response to Plaintiffs’ Renewed Motion to Exclude the Opinions and Testimony of Dr. Ellen Wright (Def.’s Resp.), ECF No. 82; Plaintiffs’ Reply to Defendant’s Brief in Opposition to Plaintiff’s Motion to Exclude the Opinions and Testimony of Dr. Ellen Wright (Pl.’s Reply), ECF No. 84; and Defendant’s Reply in Support of its Motion to Exclude the Expert Testimony of David Kassekert, P.E. (Def.’s Reply), ECF No. 86. manufactured by Little Giant Ladder Systems, LLC. On November 10, 2021, Jason Adams fell from a Little Giant ladder and suffered injuries. See Compl. ¶ 4-6. Adams asserts that he was using the ladder in the usual and ordinary manner when the rung on which he stood separated from the rest of the ladder. See Pl.’s Mot., Ex. A (“Adams Dep.”) at 165-66; Pl.’s Mem. at 2. He

testified that he inspects all ladders, he never dropped the subject ladder, and the subject ladder never fell from anything. Adams Dep. at 161-62. Defendant moved to exclude the testimony of Plaintiffs’ expert, David Kassekert, P.E., on the grounds that he is unqualified and his opinions are unreliable. Def.’s Mem. at 1. Kassekert intends to testify that a rung on the Plaintiff’s ladder failed when it separated from the side of the ladder because the welded connection did not penetrate the metal of the rung to which it was being welded, which resulted in a fatigue crack in the rung material. Def.’s Mot., Ex. 2 at 5. Because the welding was covered by plastic caps, Kassekert asserts, it was not possible for Adams to inspect the welding and see this crack. Id. Kassekert was trained as a mechanical engineer and, beyond a single college class, has little experience with welds or metallurgy. Def.’s

Mot., Ex. 1 (“Kassekert Dep.”) at 6-14; 39-40; 42-43. He said in his deposition that he has a welder and is “very good at making bad welds.” Id. at 39. He has not previously testified in any cases involving weld failures. Id. at 39. He previously worked on two ladder cases, neither of which involved an articulating ladder. Id. at 36-39. In his deposition, Kassekert said that he set the ladder up in his basement, “just spent a lot of time looking at it,” took pictures, reviewed other case materials such as Defendant’s quality assurance procedures, and “eventually started to develop an idea” that resulted in his report. Id. at 56-62. Plaintiffs moved to exclude the testimony of the Defendant’s expert, Dr. Ellen Wright, P.E., because her testimony does not comport with the facts of this case. Pl.’s Mem. at 1. Wright is a metallurgical engineering expert who specializes in failure analysis and prevention. Def.’s Resp., Ex. 3. Wright examined the subject ladder and performed destructive testing. See Def.’s Resp., Ex. 5. Plaintiffs do not contest that she is a qualified expert who used reliable scientific methods. See Pl.’s Mem. Instead, they challenge how she applied her analysis to the facts of the

case. Id. at 3. Wright intends to testify that the failure of the ladder at issue in this case was the result of a high loading event which overstressed the ladder aluminum, resulting in the detachment of the rung from the side of the ladder. Def.’s Resp. at 1; see also Def.’s Resp., Ex. 5. In her deposition, she testified that a sudden, excessive load could have occurred if someone fell on or dropped something on the ladder or if the ladder was thrown into something or thrown off a roof. Def.’s Resp., Ex. 6 (Wright Dep.) at 79-80. She does not have an opinion on the particular cause of this excessive load. Id. Plaintiffs argue that this theory is “completely speculative” and therefore should be excluded. Pl.’s Mem. at 15. In particular, Plaintiffs argue that there is nothing in Adams’ deposition testimony supporting Wright’s theory. Id. at 14. STANDARD

Rule 702 of the Federal Rules of Evidence governs the admissibility of expert witness testimony. Expert testimony is admissible if the expert is “qualified . . . by knowledge, skill, experience, training, or education,” and if his or her testimony is (1) helpful to the trier of fact in understanding the evidence or determining a fact in issue; (2) “based on sufficient facts or data”; and (3) “the product of reliable principles and methods” that (4) have been reliably applied “to the facts of the case.” Fed. R. Evid. 702. A qualified expert must have “sufficient specialized knowledge to assist the jurors in deciding the particular issues in the case.” Kumho Tire Co. v. Carmichael, 526 U.S. 137, 156 (1999) (internal quotation marks omitted). A qualified expert's testimony is admissible if it “rests on a reliable foundation and is relevant[.]” Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579, 597 (1993). The Court’s gatekeeping responsibility includes “a preliminary assessment of whether the reasoning or methodology underlying the testimony is scientifically valid and of whether that reasoning or methodology properly can be applied to the facts in issue.” Id. at 592-

93. In considering reliability, the Court must ensure that the expert opinions are “based on scientific, technical, or other specialized knowledge and not on belief or speculation, and inferences must be derived using scientific or other valid methods.” Nease v. Ford Motor Co., 848 F.3d 219, 229 (4th Cir. 2017) (italics original) (quoting Oglesby v. Gen. Motors Corp., 190 F.3d 244, 250 (4th Cir. 1999)). The party proffering the expert’s opinion has the burden of production on the question of admissibility. Maryland Cas. Co. v. Therm-O-Disc, Inc., 137 F.3d 780, 783 (4th Cir. 1998). DISCUSSION I. Kassekert The Court finds that Kassekert is not qualified to offer testimony that the ladder failed

due to an insufficient weld because he does not have sufficient specialized knowledge to opine on welds or relevant material failure.

Free access — add to your briefcase to read the full text and ask questions with AI

Adams v. Little Giant Ladder Systems, LLC, (S.D.W. Va. 2024).

Adams v. Little Giant Ladder Systems, LLC (Adams v. Little Giant Ladder Systems, LLC) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)
In Re Paoli Railroad Yard PCB Litigation
35 F.3d 717 (Third Circuit, 1994)
Bennett v. ASCO Services, Inc.
621 S.E.2d 710 (West Virginia Supreme Court, 2005)
Oglesby v. General Motors Corp.
190 F.3d 244 (Fourth Circuit, 1999)
Howard Nease v. Ford Motor Company
848 F.3d 219 (Fourth Circuit, 2017)
Jeffrey Klingenberg v. Vulcan Ladder USA, LLC
936 F.3d 824 (Eighth Circuit, 2019)