Allen v. Barratt

District Court, W.D. Washington·Decided April 8, 2025·No. 2:23-cv-00474·Unknown

Opinion

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5 6 7 8 UNITED STATES DISTRICT COURT WESTERN DISTRICT OF WASHINGTON 9 AT SEATTLE 10 11 MIRANDA ALLEN, an individual; and CASE NO. 2:23-cv-00474-TL J.M., a minor child, by and through his 12 parent, MIRANDA ALLEN, ORDER ON MOTIONS TO 13 Plaintiffs, EXCLUDE EXPERT WITNESSES v. 14 MARTIN BARRATT and J. DOE 15 BARRATT, husband and spouse and marital community composed thereof, 16 Defendants. 17

18 This is an action for damages stemming from a 2019 automobile collision. This matter is 19 before the Court on two motions: Plaintiffs’ Motion to Exclude Inadmissible Expert Opinions of 20 Defense Expert Dr. Hatzakis (Dkt. No. 25) and Defendants’ Motion to Exclude Expert 21 Testimony of Plaintiffs’ Expert Witness Dr. Leah Keylard (Dkt. No. 28). Neither party requested 22 oral argument, and the Court does not believe a hearing is necessary. See LCR 7(b)(4). Having 23 reviewed the Parties’ briefing and the relevant record, the Court DENIES Plaintiffs’ motion and 24 GRANTS Defendants’ motion. 1 I. BACKGROUND 2 This case stems from a rear-end, chain-reaction accident. Plaintiffs allege that, on or 3 about June 16, 2019, Plaintiff Allen was driving northbound on Interstate 5 in Skagit County, 4 Washington, with Plaintiff J.M. as a passenger in her vehicle. See Dkt. No. 1-1 ¶¶ 3.1–3.5. While

5 Plaintiff Allen’s vehicle was stopped in traffic, Defendant Martin Barratt, also driving 6 northbound on Interstate 5, rear-ended Plaintiff Allen’s vehicle, “caus[ing] Plaintiff Allen’s 7 vehicle to crash into the rear of the vehicle directly in front of them.” Id. ¶ 3.5. As a result of the 8 accident, Plaintiff Allen allegedly sustained substantial and permanent injuries. Id. ¶ 6.2. Plaintiff 9 J.M. also sustained injuries. Id. ¶ 6.6. 10 The Court recently discussed the procedural posture of this case in a prior Order and will 11 not duplicate that effort here. See Dkt. No. 24 at 2. However, several dates bear repeating as 12 relevant to the motions pending before the court: On March 14, 2024, the Parties filed a 13 Stipulated Motion to Continue Trial Date and Pretrial Deadlines, including deadlines for expert 14 discovery. Dkt. No. 14 at 3. On March 15, 2024, the Court granted the request (Dkt. No. 15), and

15 set a new trial schedule (Dkt. No. 16). The Parties’ deadline to disclose expert testimony under 16 Federal Rule of Civil Procedure 26(a)(2) was November 4, 2024, and the deadline for rebuttal 17 expert disclosures or reports as well as discovery motions was December 4, 2024. Dkt. No. 16 at 18 1. Discovery was to have been completed by January 3, 2025, and all motions challenging 19 expert-witness testimony were due February 3, 2025. Id. at 1–2. A jury trial in this case is 20 scheduled to begin June 2, 2025. Id. at 1. 21 On February 3, 2025, the Parties timely filed respective motions to exclude expert 22 testimony. First, Plaintiffs filed a motion to exclude the expert testimony of Dr. Michael 23 Hatzakis, Defendants’ physiatrist expert. Dkt. No. 25. Later that day, Defendants filed a motion

24 1 to exclude the expert testimony of Dr. Leah Keylard, Plaintiffs’ audiologist expert. Dkt. No. 28. 2 The Parties filed responses (Dkt. Nos. 29, 32) and reply briefs (Dkt. Nos. 33, 34). 3 II. LEGAL STANDARD 4 A. Federal Rule of Evidence 702

5 Federal Rule of Evidence (“FRE”) 702 provides that “a witness who is qualified as an 6 expert by knowledge, skill, experience, training, or education may testify” if: 7 (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or 8 to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles 9 and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case. 10

11 Fed. R. Evid. 702. This rule imposes an obligation on the court to act as a gatekeeper and 12 evaluate the admissibility of expert opinion testimony by ensuring that such evidence is both 13 relevant and reliable. See Kumho Tire Co. v. Carmichael, 526 U.S. 137, 147 (1999) (quoting 14 Daubert v. Merrell Dow Pharms., Inc. (Daubert I), 509 U.S. 579, 589 (1993)); see also Est. of 15 Barabin v. AstenJohnson, Inc., 740 F.3d 457, 463 (9th Cir. 2014) (en banc) (“We have 16 interpreted [FRE] 702 to require that ‘[e]xpert testimony . . . be both relevant and reliable.’” 17 (alteration in original) (quoting United States v. Vallejo, 237 F.3d 1008, 1019 (9th Cir. 2001))), 18 overruled on other grounds by United States v. Bacon, 979 F.3d 766 (9th Cir. 2020) (en banc). 19 “Expert opinion testimony is relevant if the knowledge underlying it has a valid 20 connection to the pertinent inquiry.” Alaska Rent-A-Car, Inc. v. Avis Budget Grp., Inc., 738 F.3d 21 960, 969 (9th Cir. 2013) (quoting Primiano v. Cook, 598 F.3d 558, 565 (9th Cir. 2010)). Expert 22 opinion “is reliable if the knowledge underlying it has a reliable basis in the knowledge and 23 experience of the relevant discipline.” Id. (quoting Primiano, 598 F.3d at 565); see also Gen. 24 Elec. Co. v. Joiner, 522 U.S. 136, 146 (1997) (noting opinion evidence “that is connected to 1 existing data only by the ipse dixit of the expert” should not be admitted, or where there is 2 “simply too great an analytical gap between the data and the opinion proffered”). 3 To assess the reliability of an expert opinion, courts ordinarily look to such factors as: 4 (1) whether the expert’s theory or technique can be tested; (2) whether it has been subjected to

5 peer review and publication; (3) its known or potential error rate; and (4) whether it enjoys 6 general acceptance within the relevant community. Est. of Barabin, 740 F.3d at 463 (citing 7 Daubert I, 509 U.S. at 592–94) (“The Supreme Court has suggested several factors that can be 8 used to determine the reliability of expert testimony . . . .”). This is a flexible inquiry, however, 9 and the trial court has discretion to decide how to assess the reliability of opinion testimony 10 based on the particular circumstances of each case. Primiano, 598 F.3d at 564 (quoting Kumho 11 Tire Co., 526 U.S. at 150, 152). The court may, but is not required to, hold a “Daubert hearing” 12 to determine the relevance and reliability of an expert opinion. See Jones v. Riot Hosp. Grp. 13 LLC, 95 F.4th 730, 737 (9th Cir. 2024); Est. of Barabin, 740 F.3d at 463–64. 14 Notably, “[t]he test under Daubert is not the correctness of the expert’s conclusions but

15 the soundness of his methodology.” Primiano, 598 F.3d at 564 (quoting Daubert v. Merrell Dow 16 Pharms., Inc. (Daubert II), 43 F.3d 1311, 1313 (9th Cir. 1995), on remand from Daubert I, 509 17 U.S. 579 (1993)).

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