Cleaveland v. Home Depot USA, Inc.

CourtCourt of Appeals for the Second Circuit
DecidedApril 2, 2026
Docket25-1582
StatusUnpublished

This text of Cleaveland v. Home Depot USA, Inc. (Cleaveland v. Home Depot USA, Inc.) is published on Counsel Stack Legal Research, covering Court of Appeals for the Second Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cleaveland v. Home Depot USA, Inc., (2d Cir. 2026).

Opinion

25-1582-cv Cleaveland v. Home Depot USA, Inc.

UNITED STATES COURT OF APPEALS FOR THE SECOND CIRCUIT

SUMMARY ORDER

RULINGS BY SUMMARY ORDER DO NOT HAVE PRECEDENTIAL EFFECT. CITATION TO A SUMMARY ORDER FILED ON OR AFTER JANUARY 1, 2007, IS PERMITTED AND IS GOVERNED BY FEDERAL RULE OF APPELLATE PROCEDURE 32.1 AND THIS COURT’S LOCAL RULE 32.1.1. WHEN CITING A SUMMARY ORDER IN A DOCUMENT FILED WITH THIS COURT, A PARTY MUST CITE EITHER THE FEDERAL APPENDIX OR AN ELECTRONIC DATABASE (WITH THE NOTATION “SUMMARY ORDER”). A PARTY CITING A SUMMARY ORDER MUST SERVE A COPY OF IT ON ANY PARTY NOT REPRESENTED BY COUNSEL.

At a stated term of the United States Court of Appeals for the Second Circuit, held at the Thurgood Marshall United States Courthouse, 40 Foley Square, in the City of New York, on the 2nd day of April, two thousand twenty-six.

PRESENT: RAYMOND J. LOHIER, JR., STEVEN J. MENASHI, SARAH A. L. MERRIAM, Circuit Judges. ------------------------------------------------------------------ JOSHUA CLEAVELAND,

Plaintiff-Appellant,

v. No. 25-1582-cv

HOME DEPOT USA, INC., TRICAM INDUSTRIES, INC.,

Defendants-Appellees.

------------------------------------------------------------------

1 FOR PLAINTIFF-APPELLANT: JACK G. STEIGELFEST, Howard, Kohn, Sprague & FitzGerald LLP, Hartford, CT

FOR DEFENDANTS-APPELLEES: JONATHAN R. SICHTERMANN, Parsky & Galloway, LLC, Chicago, IL

Appeal from a judgment of the United States District Court for the District

of Connecticut (Sarala V. Nagala, Judge).

UPON DUE CONSIDERATION, IT IS HEREBY ORDERED, ADJUDGED,

AND DECREED that the judgment of the District Court is AFFIRMED.

Plaintiff Joshua Cleaveland appeals from the June 10, 2025 judgment of the

United States District Court for the District of Connecticut (Nagala, J.) granting

the motions by the Defendants, Home Depot USA, Inc. and Tricam Industries,

Inc., to exclude the testimony of Cleaveland’s expert, Dr. Jonathan Slocum, and

for summary judgment. Cleaveland also challenges the District Court’s order

denying his motion for leave to supplement his expert report. We assume the

parties’ familiarity with the underlying facts and the record of prior proceedings,

to which we refer only as necessary to explain our decision to affirm.

Cleaveland was injured after falling off a Tricam Model GLX-5B ladder

(the “Tricam ladder”) that had been manufactured and sold by the Defendants.

Cleaveland originally sued in state court under the Connecticut Product Liability

2 Act, Conn. Gen. Stat. § 52-572m et seq., and the Defendants removed the action to

federal court on the basis of diversity jurisdiction. In November 2024, one month

after the close of all discovery, Cleaveland moved for leave to supplement the

initial report of his expert, Dr. Slocum. The District Court denied the motion. In

June 2025 the District Court granted the Defendants’ motions to exclude Dr.

Slocum’s initial expert report and for summary judgment.

I. Motion to Supplement

Cleaveland first argues that the District Court erred in denying his motion

to supplement Dr. Slocum’s expert report. In excluding the untimely

supplemental report, the District Court relied on Federal Rule of Civil Procedure

37(c)(1), which provides that a party that fails to disclose information as required

under Rule 26(a) “is not allowed to use that information . . . to supply evidence

on a motion . . . unless the failure was substantially justified or is harmless.” Fed.

R. Civ. P. 37(c)(1). We review the District Court’s exclusion of testimony under

Rule 37(c)(1) for abuse of discretion. See Patterson v. Balsamico, 440 F.3d 104, 117

(2d Cir. 2006).

Cleaveland asks us to view the District Court’s denial of his motion to

supplement Dr. Slocum’s report as akin to a dismissal, which we have called “a

3 drastic remedy that should be imposed only in extreme circumstances, usually

after consideration of alternative, less drastic sanctions.” World Wide Polymers,

Inc. v. Shinkong Synthetic Fibers Corp., 694 F.3d 155, 159 (2d Cir. 2012) (cleaned

up). We are unpersuaded. The District Court’s denial of Cleaveland’s motion to

supplement neither eliminated any of Cleaveland’s claims nor precluded

Cleaveland from relying on Dr. Slocum’s initial report. See id. (describing a

district court’s decision to strike a request for damages as “akin to dismissing the

action altogether”). Indeed, Cleaveland continued to litigate his claims for

several months after the denial, and the District Court reviewed additional

briefing and heard oral argument. Contrary to Cleaveland’s assertions,

therefore, the denial of leave to file a supplemental expert report was not

tantamount to dismissal.

Nor are we persuaded that the District Court abused its discretion in

denying Cleaveland’s motion to supplement under Rule 37(c)(1). In assessing

the denial, we consider “(1) the party’s explanation for the failure to comply with

the disclosure requirement; (2) the importance of the testimony of the precluded

witnesses; (3) the prejudice suffered by the opposing party . . .; and (4) the

possibility of a continuance.” Patterson, 440 F.3d at 117 (cleaned up). Cleaveland

4 never explained when he learned that his expert would need more time and why

he did not promptly notify the District Court after learning that his expert

needed more time. And, as Cleaveland acknowledges, the late disclosure

prejudiced the Defendants, who had already moved for summary judgment. On

this record, we cannot say that the District Court exceeded its “wide discretion”

under Rule 37(c)(1) in denying Cleaveland’s motion to supplement. See Outley v.

City of New York, 837 F.2d 587, 590 (2d Cir. 1988).

II. Exclusion of Expert Testimony

Cleaveland next argues that the District Court erred in excluding

Dr. Slocum’s initial expert report under Rule 702 of the Federal Rules of

Evidence. “We review a district court’s decision to . . . exclude expert testimony

under a highly deferential abuse of discretion standard.” Bustamante v. KIND,

LLC, 100 F.4th 419, 426 (2d Cir. 2024) (quotation marks omitted). The decision to

exclude expert testimony “is not an abuse of discretion unless it is manifestly

erroneous.” Amorgianos v. Nat’l R.R. Passenger Corp., 303 F.3d 256, 265 (2d Cir.

2002) (quotation marks omitted).

It was not manifestly erroneous for the District Court to exclude Dr.

Slocum’s initial report on the ground that his conclusions were speculative. In

5 concluding that a defect in the Tricam ladder had caused Cleaveland’s injury, Dr.

Slocum stated only that he had “visually inspected” the ladder, measured its

“height/wall thickness ratio,” and “reviewed an exemplar ladder.” Joint App’x

66–68. Because “[t]he failure to test a theory of causation can justify a trial

court’s exclusion of the expert’s testimony,” Brooks v. Outboard Marine Corp., 234

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Related

Outley v. City of New York
837 F.2d 587 (Second Circuit, 1988)
Baltas v. Maiga
119 F.4th 255 (Second Circuit, 2024)
Fajardo v. Boston Scientific Corp.
Supreme Court of Connecticut, 2021

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