In re: East Palestine Train Derailment

District Court, N.D. Ohio·Decided January 24, 2025·No. 4:23-cv-00242·Unknown

Opinion

PEARSON, J. UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF OHIO EASTERN DIVISION

IN RE: EAST PALESTINE TRAIN ) DERAILMENT ) CASE NO. 4:23CV0242 JUDGE BENITA Y. PEARSON MEMORANDUM OF OPINION ) AND ORDER ) [Resolving ECF No. 629]

Pending is Third-Party Plaintiffs Norfolk Southern Corporation and Norfolk Southern Railway Company’s (collectively “Norfolk Southern”) Motion to Exclude the Expert Report and Testimony of James H. Rader (ECF No. 629) proffered by Third-Party Defendants GATX Corporation and General American Marks Company (“GATX”). The Court has been advised, having reviewed the record, the parties’ briefs, and the applicable law. For the reasons that follow, the motion is denied. 1. GPLX 75465 (Car 23) - the railcar owned by GATX' — was added to Train 32N at the Terminal Railroad Association of St. Louis’s (“TRRA”) terminal in Madison, Illinois. TRRA, not Norfolk Southern, was obligated to inspect Train 32N before it departed Madison. See Deposition of James H. Rader (ECF No. 629-4) at PageID #: 37936:20 - PageID #: 37937:3. Before it derailed in East Palestine, Train 32N passed over a series of hot bearing detectors (“HBDs”) that monitor the radiant temperatures of a train’s roller bearings to prevent

' See Stipulation Regarding Uncontested Facts (ECF No. 586) at PagelD #: 17627, Yj 3-4; see also Stipulation (ECF No. 740).

(4:23CV0242) derailments. A Norfolk Southern HBD in Salem, Ohio recorded a bearing temperature spike on the L1 wheel of GPLX 75465 — whose failed roller bearing caused the derailment on February 3, 2023. GATX argues that Train 32N derailed in East Palestine because Norfolk Southern’s HBD system failed to inform the crew of a bearing temperature spike, which would have caused the crew to stop the train. Gary Rambo — the wayside analyst on duty when Train 32N derailed — missed the 953 alert” at the Salem detector because he was preoccupied with alerts from five other trains. See Deposition of Gary Rambo (ECF No. 622-6) at PageID #: 33458; 33463. The crew of Train 32N testified that had they been informed of the 953 alert at the Salem detector, they would have stopped the train before it derailed in East Palestine. See Deposition of Kevin Stauffer (ECF No. 622-7) at PageID #: 33626; Deposition of Michael Anthony Faison (ECF No. 622-5) at PageID #: 33401; Deposition of Javon Jordan Dep. Tr. (ECF No. 622-8) at □□□□□□ #: 33712. II. The Federal Rules of Evidence, and specifically Rule 702, “assign to the trial judge the task of ensuring that an expert’s testimony both rests on a reliable foundation and is relevant to the task at hand.” Daubert v. Merrill Dow Pharm., Inc., 509 U.S. 579, 597 (1993). Rule 702 governs the admissibility of expert testimony and codifies the Supreme Court’s holdings in Daubert and Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (1999). Expert testimony is admissible only if (1) the testimony is based on sufficient facts or data, (2) the testimony is the

> “A 953 Alert indicates a bearing temperature spike.” Opposing Expert Report of James H. Rader (ECF No. 629-3) at PageID #: 37743 (citing Deposition of Thomas Fox (ECF No. 622-4) at PageID #: 33286; NS-CA-000692637, p. 1 (953 Alert (Bearing Temperature Spike)’).

(4:23CV0242) product of reliable principles and methods, and (3) the expert has reliably applied the principles and methods to the facts of the case. Fed. R. Evid. 702. The proponent of the expert testimony has the burden of establishing by a preponderance of the evidence that the proposed testimony satisfies those standards. See Fed. R. Evid. 702 advisory committee’s note (2000); Daubert, 509 U.S. at 592 n.10. Expert testimony is not admissible “is the exception rather than the rule.” □□ re Scrap Metal Antitrust Litig., 527 F.3d 517, 530 (6th Cir. 2008) (quoting Fed. R. Evid. 702 advisory committee’s note (2000)). Furthermore, a Daubert analysis includes consideration of Fed. R. Evid. 403. Daubert, 509 U.S. at 595. Therefore, courts in the Sixth Circuit employ a four prong test to determine the admissibility of expert opinions: “(1) that the witness, a qualified expert, (2) was testifying to a proper subject, (3) which conformed to a generally accepted explanatory theory, and (4) the probative value of the testimony outweighed its prejudicial effect.” United States v. Smithers, 212 F.3d 306, 312 (6th Cir. 2000) (citing United States v. Green, 548 F.2d 1261 (6th Cir.1977)). Ii. Rader has “more than 45 years of railroad related experience.” ECF 629-3 at PageID #: 37736, § 1, 9.1.2. He began his career as a railcar inspector over 40 years ago and has “been inspecting cars ever since.” ECF 629-4 at PageID #: 37794:20-22; PageID #: 37795:16-20. That experience spans railroad safety, regulation, and operations, including, among other areas, railcar inspection and maintenance, auditing of inspection and maintenance practices, assistance with accident investigations, and developing and ensuring regulatory compliance. See ECF 629-3 at PageID #: 37736, § 1,9 1.2. Rader has decades of experience inspecting railcars, including as both a carman in the field and, more recently, a consultant. See ECF 629-4 at PageID #:

(4:23CV0242) 37794:20-22; PageID #: 37795:16-20. Over the years, he has also gained “practical industry experience” with HBDs in working on behalf of railcar owners who rely on the accuracy of the data generated by HBDs and who rely on railroads to respond appropriately to that data in real time. ECF No. 629-4 at PageID #: 38002:5-21; PageID #: 37879:5-14. He opines on how Norfolk Southern’s policies and practices — specifically as they relate to pre-departure inspections and HBDs - contributed to Train 32N’s derailment. Specifically, Rader opines that “Norfolk Southern failed to validate that TRRA performed a required inspection of Train 32N,” deviating from industry standards, and thus “created gaps in the inspection and recordkeeping process that may have prevented the derailment.” ECF 629-3 at PageID #: 37737, § 2, 4 2; PageID #: 37751, § 5. Rader also opines that “Norfolk Southern failed to properly setup its Wayside Detector System and improperly staffed its Wayside Desk,” which “prevent[ed] the crew from learning that the L1 bearing was overheated, with what appeared on contemporaneous video to be molten metal and fire emanating from the L1 bearing, when it passed the Salem detector and stopping the train.” ECF No. 629-3 at PageID #: 37737, § 2,41. Applying his experience in railcar inspection and documentation practices, Rader concludes that Norfolk Southern failed to act consistent with what its own corporate representative called a “good practice” in maintaining records of pre-departure inspections.’ ECF 629-3 at PageID #: 37752, 37754-55. That, in turn, prevented Norfolk Southern from verifying that a proper pre-departure mechanical inspection of GPLX 75465 had even been conducted.

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