Houser v. Oceaneering International Inc

CourtDistrict Court, W.D. Louisiana
DecidedAugust 8, 2022
Docket6:20-cv-00197
StatusUnknown

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

Bluebook
Houser v. Oceaneering International Inc, (W.D. La. 2022).

Opinion

UNITED STATES DISTRICT COURT WESTERN DISTRICT OF LOUISIANA

LAFAYETTE DIVISION DARRYL HOUSER CASE NO. 6:20-CV-00197 VERSUS JUDGE SUMMERHAYS

OCEANEERING INTERNATIONAL INC. MAG. JUDGE WHITEHURST

MEMORANDUM RULING Pending before the undersigned magistrate judge are two motions filed by the defendant Oceaneering International, Inc. (“hereinafter, “defendant”), as follows: (1) Motion in Limine to Exclude YouTube Videos of Other Bottles Exploding [Doc. 30]

and (2) Motion in Limine to Exclude Certain Video Audio Samples [Doc. 31]. Both motions are opposed [Docs. 37 & 36, respectively], and reply briefs were filed in response to each opposition [Docs. 40 & 39, respectively]. Additionally, plaintiff filed two sur-replies to the instant motions [Docs. 47 & 46, respectively]. Plaintiff’s

Motion for Leave to File Supplement to Sur-Reply Memorandum in Opposition to Defendant’s Motion in Limine [Doc. 52] is DENIED. For the following reasons, the Motion in Limine to Exclude YouTube Videos of Other Bottles Exploding [Doc.

−1− 30] is GRANTED, and the Motion in Limine to Exclude Certain Video Audio Samples [Doc. 31] is DENIED.

FACTUAL AND PROCEDURAL BACKGROUND The instant litigation arises out of an alleged incident that occurred on February 28, 2019. The plaintiff, an employee of defendant Oceaneering, alleges

that he was injured when “. . . an improperly sealed plastic water bottle ascending from approximately 380’ of sea water in an equipment locker near plaintiff’s head after he opened the saturation equipment lock to remove equipment out of the lock.”1 The plaintiff alleges that he suffered disabling tinnitus in both ears, as well as

vestibular injury, as a result of this blast injury when the water bottle exploded near his head. LAW AND ANALYSIS

1. Motion in Limine to Exclude YouTube Videos of Other Bottles Exploding [Doc. 30]

During the course of discovery, the plaintiff revealed that he was in possession of a link to a YouTube video of a plastic bottle exploding due to air pressure being

1 See plaintiff’s opposition brief, Doc. 36, at p. 2.

−2− pumped into the plastic bottle. The YouTube video features a test conducted by a television presenter on the BBC network in 2010.2 The plaintiff has indicated that,

after laying a proper foundation for the video, he intends to offer the video at trial as evidence, either through plaintiff’s testimony or the testimony of an expert witness. In the instant motion, the defendant seeks to exclude this YouTube video at trial, as

well as any testimony based on the video, on grounds that a proper foundation cannot be laid for the video, which is unfairly prejudicial and of no probative value. Both parties agree that the admissibility of expert testimony is governed by Rule 702 of the Federal Rules of Evidence, which provides:

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:

(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

2 A webpage link was provided to the undersigned for an in camera inspection in connection with the pending motion, which has been conducted.

−3− (d) the expert has reliably applied the principles and methods to the facts of the case.

Fed. R. Evid. 702. In Daubert v. Merrell Dow Pharmaceuticals, Inc., the Supreme Court instructed courts to function as gatekeepers, and determine whether expert testimony should be presented to the jury. 509 U.S. 579, 590–93, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993). Courts act as gatekeepers of expert testimony “to make certain that an expert, whether basing testimony upon professional studies or personal experience, employs in the courtroom the same level of intellectual rigor

that characterizes the practice of an expert in the relevant field.” Kumho Tire Co. v. Carmichael, 526 U.S. 137, 152, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999). The party offering the expert's testimony has the burden to prove that: (1) the

expert is qualified; (2) the testimony is relevant to an issue in the case; and (3) the testimony is reliable. Daubert, 509 U.S. at 590–91, 113 S.Ct. 2786. A proffered expert witness is qualified to testify by virtue of his or her “knowledge, skill, experience, training, or education.” Fed. R. Evid. 702. Moreover, to be

admissible, expert testimony must be “not only relevant but reliable.” Daubert, 509 U.S. at 589, 113 S.Ct. 2786. “This gate-keeping obligation applies to all types of

−4− expert testimony, not just scientific testimony.” Pipitone v. Biomatrix, Inc., 288 F.3d 239, 244 (5th Cir. 2002), citing Kumho, 526 U.S. at 147, 119 S.Ct. 1167.

In Daubert, the Supreme Court offered the following, non-exclusive list of factors that courts may use when evaluating the reliability of expert testimony: (1) whether the expert's theory or technique can be or has been tested; (2) whether the

theory or technique has been subjected to peer review and publication; (3) the known or potential rate of error of the challenged method; and (4) whether the theory or technique is generally accepted in the relevant scientific community. Id. at 593–94, 113 S.Ct. 2786; Pipitone, 288 F.3d at 244. When evaluating Daubert challenges,

courts focus “on [the experts’] principles and methodology, not on the conclusions that [the experts] generate.” Daubert, 509 U.S. at 595, 113 S.Ct. 2786. The Daubert factors are not “a definitive checklist or test.” Id. at 593, 113

S.Ct. 2786. As the Supreme Court has emphasized, the Daubert framework is “a flexible one.” Id. at 594, 113 S.Ct. 2786. The test for determining reliability can adapt to the particular circumstances underlying the testimony at issue. Kumho, 526 U.S. at 152, 119 S.Ct. 1167. Accordingly, the decision to allow or exclude

experts from testifying under Daubert is committed to the sound discretion of the

−5− district court. St. Martin v. Mobil Expl. & Producing U.S., Inc., 224 F.3d 402, 405 (5th Cir. 2000) (citations omitted).

The foregoing rules unquestioningly apply in jury trials, however the Fifth Circuit has indicated that most of the safeguards provided for in Daubert are not as essential in a case such as this where a district judge sits as the trier of fact in place

of a jury. See, e.g., Gibbs v. Gibbs, 210 F.3d 491, 500 (5th Cir. 2000). See also Whitehouse Hotel Ltd. P'ship v. Comm'r, 615 F.3d 321, 330 (5th Cir. 2010) (when there is no jury, “there is no risk of tainting the trial by exposing a jury to unreliable evidence.”).

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