Gallagher v. Lucas

CourtDistrict Court, W.D. Texas
DecidedOctober 30, 2020
Docket5:20-cv-00072
StatusUnknown

This text of Gallagher v. Lucas (Gallagher v. Lucas) is published on Counsel Stack Legal Research, covering District Court, W.D. Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gallagher v. Lucas, (W.D. Tex. 2020).

Opinion

IN THE UNITED STATES DISTRICT COURT FOR THE WESTERN DISTRICT OF TEXAS SAN ANTONIO DIVISION

KAREN GALLAGHER, § § Plaintiff, § SA-20-CV-00072-FB § vs. § § GEORGE E LUCAS JR, § § Defendant. §

ORDER Before the Court in the above-styled cause of action is Plaintiff’s Motion to Strike Portions of the Testimony of John R. Anderson, M.D. [#30], by which Plaintiff asks the Court to limit the testimony of John R. Anderson, M.D., Defendant’s retained medical expert. This case was referred to the undersigned for all pretrial proceedings on February 27, 2020 [#5]. Therefore, the undersigned has authority to issue this order pursuant to 28 U.S.C. § 636(b)(1)(A). The Court held a telephonic hearing on the motion on October 22, 2020, at which Plaintiff and Defendants appeared through counsel and at which Dr. Anderson provided live testimony. At the close of the hearing, the Court issued certain oral rulings, which are now memorialized with this written Order. I. Background This lawsuit arises out of a motor-vehicle accident occurring on November 26, 2018 on Interstate 10 in Seguin, Texas. Plaintiff Karen Gallagher a/k/a Karen Schmitz filed this lawsuit against Defendant George E. Lucas, Jr., alleging various theories of negligence related to the accident. According to the Amended Complaint before the Court, Plaintiff was a passenger in a vehicle struck by Defendant’s truck and suffered severe and permanent bodily injuries. Defendant designated Dr. Anderson, a board-certified orthopedic surgeon, as a medical expert to opine on Plaintiff’s injuries, the causation and source of her injuries, the necessity of treatment, and the reasonableness of cost. (Expert Designation [#19] at 3.) Medical records indicate that Plaintiff has been receiving treatment for injury to her cervical and lumbar spine since the accident and that Dr. Frank Kuwamura has recommended Plaintiff undergo two lumbar

spine surgeries (sacroiliac joint fusion and a 360-degree fusion from L3 to the sacrum) at a projected cost of $469,451 and $163,763, respectively. After reviewing the incident report associated with the accident, photos of the damaged vehicle, the pleadings and discovery exchanged in this case, the parties’ deposition transcripts, and Plaintiff’s medical records and bills, Dr. Anderson concluded that the evidence fails to support Plaintiff’s claim of substantial injury from the accident at issue and that Plaintiff has preexisting degenerative disease of the spine. (Anderson Expert Report [#19-1] at 15–16.) Plaintiff now moves to limit Dr. Anderson’s testimony under Daubert and Rule 702 of the Federal Rules of Evidence, arguing that Dr. Anderson should not be permitted to testify on

the biomechanics of the accident or the projected cost of spinal surgery. Plaintiff does not seek to limit Dr. Anderson’s testimony interpreting the extent of Plaintiff’s injuries and the necessity of medical treatment, including the recommended spinal surgeries. II. Legal Standard for Admissibility of Expert Opinions In Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579, 589 (1993), the Supreme Court held that trial judges must ensure that any and all scientific testimony or evidence admitted is not only relevant, but reliable. Subsequent to Daubert, Rule 702 of the Federal Rules of Evidence was amended to provide that a witness “qualified as an expert . . . may testify . . . in the form of an opinion . . . if (1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case.” See Guy v. Crown Equipment Corp., 394 F.3d 320, 325 (5th Cir. 2004) (quoting Fed. R. Evid. 702). The Rule 702 and Daubert analysis applies to all proposed expert testimony, including nonscientific “technical analysis” and other “specialized knowledge.” Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137, 141

(1999). Under Daubert, expert testimony is admissible only if the proponent demonstrates that: (1) the expert is qualified; (2) the evidence is relevant to the suit; and (3) the evidence is reliable. See Moore v. Ashland Chem. Inc., 151 F.3d 269, 276 (5th Cir. 1998); Watkins v. Telsmith, Inc., 121 F.3d 984, 989 (5th Cir. 1997). The overarching focus of a Daubert inquiry is the “validity and thus evidentiary relevance and reliability of the principles that underlie a proposed submission.” Watkins, 121 F.3d at 989 (quoting Daubert, 509 U.S. at 594–96). Because the Daubert test focuses on the underlying theory upon which the opinion is based, the proponent of expert testimony need not prove the expert’s testimony is correct, but rather that the testimony is

reliable. Moore, 151 F.3d at 276. This determination of reliability includes a preliminary determination 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.” Daubert, 509 U.S. at 592–93. Daubert sets forth four specific factors that the trial court should ordinarily apply when considering the reliability of scientific evidence: (1) whether the technique can or has been tested; (2) whether it has been subjected to peer review or publication; (3) whether there is a known or potential rate of error; and (4) whether the relevant scientific community generally accepts the technique. Id. This test of reliability, however, is “flexible,” and these factors “neither necessarily nor exclusively apply to all experts or in every case.” Kumho Tire Co., 526 U.S. at 141. “Rather, the law grants a district court the same broad latitude when it decides how to determine reliability as it enjoys in respect to its ultimate reliability determination.” Id. at 142. “The proponent need not prove that the expert’s testimony is correct, but she must prove by a preponderance of the evidence that the testimony is reliable.” Moore, 151 F.3d at 276.

Notwithstanding the testing of an expert’s qualification, reliability, and admissibility, “the rejection of expert testimony is the exception rather than the rule.” Fed. R. Evid. 702, Adv. Comm. Notes (2000). Daubert did not work a “seachange over federal evidence law,” and “the trial court’s role as gatekeeper is not intended to serve as a replacement for the adversary system.” Id. (quoting United States v. 14.38 Acres of Land, 80 F.3d 1074, 1078 (5th Cir. 1996)). “Vigorous cross-examination, presentation of contrary evidence, and careful instruction on burden of proof are the traditional and appropriate means of attacking shaky but admissible evidence.” Daubert, 509 U.S. at 596. III. Analysis

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Related

Watkins v. Telsmith, Inc.
121 F.3d 984 (Fifth Circuit, 1997)
Moore v. Ashland Chemical Inc.
151 F.3d 269 (Fifth Circuit, 1998)
Guy v. Crown Equipment Corp.
394 F.3d 320 (Fifth Circuit, 2004)
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)

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Bluebook (online)
Gallagher v. Lucas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gallagher-v-lucas-txwd-2020.