FRIEDMAN v. CENTRAL MAINE POWER COMPANY

CourtDistrict Court, D. Maine
DecidedMarch 28, 2024
Docket2:20-cv-00237
StatusUnknown

This text of FRIEDMAN v. CENTRAL MAINE POWER COMPANY (FRIEDMAN v. CENTRAL MAINE POWER COMPANY) is published on Counsel Stack Legal Research, covering District Court, D. Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
FRIEDMAN v. CENTRAL MAINE POWER COMPANY, (D. Me. 2024).

Opinion

UNITED STATES DISTRICT COURT DISTRICT OF MAINE

ED FRIEDMAN, ) ) Plaintiff, ) ) v. ) 2:20-cv-00237-JDL ) CENTRAL MAINE POWER ) COMPANY, ) ) Defendant. )

ORDER ON MOTIONS TO EXCLUDE EXPERT WITNESS TESTIMONY Ed Friedman brings this action against Central Maine Power Company (“CMP”) for allegedly violating the Americans with Disabilities Act, the Rehabilitation Act, and the Fair Housing Act by charging him a monthly fee to opt out of CMP’s program to replace analog meters with “smart meters” to measure customer electricity usage remotely. Friedman, who has a rare form of non-Hodgkin’s lymphoma, argues that waiving the opt-out fee is a reasonable accommodation to avoid exacerbating his cancer prognosis and associated symptoms through exposure to radiofrequency (“RF”) radiation that a CMP smart meter will emit if installed on his property. Both Friedman and CMP have retained expert witnesses and move to exclude testimony from all or a portion of their adversary’s experts under Federal Rule of Evidence 702 and Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993). I. PROCEDURAL HISTORY After Friedman brought this action in July 2020 (ECF No. 1), CMP moved to dismiss the claims against it for failure to state a claim (ECF No. 11). I denied CMP’s motion while noting that “Friedman must eventually prove . . . that having a smart meter installed at his home actually risks worsening his lymphoma’s progression or symptoms” to ultimately prevail. ECF No. 26 at 9. The parties completed discovery

and designated several expert witnesses to support their positions. Friedman designated four experts: Dr. David Carpenter, a public health physician and professor of environmental health science; Dr. Paul Héroux, a physicist and professor of health science; Erik Anderson, an electrical engineer; and Dr. Kent Chamberlin, a professor of electrical and computer engineering. CMP enlisted an expert lineup that included, among others, Dr. Robert Gale, a medical doctor and academic who has published on

topics including cancer biology and radiation biology. On March 29, 2023, CMP filed a notice of intent to move for summary judgment and to exclude or limit the testimony of each of Friedman’s four designated experts (ECF No. 86), and Friedman moved to exclude Dr. Gale’s testimony shortly thereafter (ECF No. 91). Pursuant to Local Rule 56(h), I held a case management conference with the parties on May 17, 2023 (ECF No. 96) and issued a report after explaining that I would decide the parties’ Daubert motions before setting a schedule for

summary judgment practice (ECF No. 97). CMP subsequently moved to exclude or limit the testimony of Dr. Carpenter, Mr. Anderson, Dr. Chamberlin, and Dr. Héroux (ECF Nos. 99, 100, 101, 102). I held oral argument on the five pending Daubert motions on August 31, 2023 (ECF No. 123). II. LEGAL STANDARD Federal Rule of Evidence 702 governs expert witness testimony and provides the framework for assessing the parties’ pending motions. Rule 702 provides in full:

A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if the proponent demonstrates to the court that it is more likely than not that: (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or 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 and methods; and (d) the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.

Fed. R. Evid. 702.1 As a threshold matter, Rule 702 requires “that a putative expert be qualified to testify by knowledge, skill, experience, training or education.” Levin v. Dalva Bros., Inc., 459 F.3d 68, 78 (1st Cir. 2006). Because courts interpret Rule 702 “liberally in favor of the admission of expert testimony . . . expert witnesses need not have overly specialized knowledge to offer opinions.” Id.; see also Daubert, 509 U.S. at 588 (recognizing the “‘liberal thrust’ of the Federal Rules” of Evidence broadly—and Rule 702 specifically—as well as the Rules’ “general approach of relaxing the traditional barriers to ‘opinion’ testimony” (quoting Beech Aircraft Corp. v. Rainey, 488 U.S. 153, 169 (1988)). Still, a witness qualified as expert on certain topics “does not mean that he or she is qualified to express expert opinions as to other fields.” Levin, 459 F.3d at 78 (quoting Nimely v. City of New York, 414 F.3d 381, 399 n.13 (2d Cir. 2005) (alteration omitted)). Courts, therefore, should exclude proffered opinions that are

1 The most recent amendments to Federal Rule of Evidence 702 became effective December 1, 2023. This Order references Rule 702’s current language. outside the witness’s established expertise as circumscribed by one or more of the five bases in Rule 702. Id. Beyond establishing the bases for qualification, the purpose of Rule 702 is to

probe the “validity and thus the evidentiary relevance and reliability” of the principles and methodology underlying proffered expert testimony. Daubert, 509 U.S. at 594-95. Subsection (a) of the rule speaks to the relevance or “fit” of the proposed testimony; its “‘helpfulness’ standard requires a valid scientific connection to the pertinent inquiry as a precondition to admissibility.” Id. at 591-92. Evidence is relevant if it has “any tendency to make the existence of any fact that is of

consequence to the determination of the action more probable or less probable than it would be without the evidence.” Id. at 587 (quoting Fed. R. Evid. 401 prior to its amendment effective Dec. 1, 2011). Subsections (b), (c), and (d) of Rule 702 speak to reliability. See Fed. R. Evid. 702 advisory committee’s note to 2023 amendments. “Reliability” in this context means “evidentiary reliability—that is, trustworthiness.” Daubert, 509 U.S. at 590 n.9. “In a case involving scientific evidence, evidentiary reliability will be based upon

scientific validity”—i.e., whether “the principle support[s] what it purports to show[.]” Id. Factors that may inform a reliability determination include: “(1) whether the theory or technique can be and has been tested; (2) whether the technique has been subject to peer review and publication; (3) the technique’s known or potential rate of error; and (4) the level of the theory or technique’s acceptance within the relevant discipline.” United States v. Mooney, 315 F.3d 54, 62 (1st Cir. 2002) (citing Daubert, 509 U.S. at 593-94). Which Daubert factors are pertinent to assessing reliability “depend[s] on the nature of the issue, the expert’s particular expertise, and the subject of his testimony.” Milward v. Acuity Specialty Prods. Grp. Inc.,

Related

Beech Aircraft Corp. v. Rainey
488 U.S. 153 (Supreme Court, 1988)
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)
United States v. Mooney
315 F.3d 54 (First Circuit, 2002)
Levin v. Dalva Brothers, Inc.
459 F.3d 68 (First Circuit, 2006)
Milward v. Acuity Specialty Products Group, Inc.
639 F.3d 11 (First Circuit, 2011)
Nimely v. City of New York
414 F.3d 381 (Second Circuit, 2005)

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