John Doe v. P Trustees of Dartmouth College

2023 DNH 131
CourtDistrict Court, D. New Hampshire
DecidedOctober 18, 2023
Docket22-cv-018-LM
StatusPublished

This text of 2023 DNH 131 (John Doe v. P Trustees of Dartmouth College) is published on Counsel Stack Legal Research, covering District Court, D. New Hampshire primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
John Doe v. P Trustees of Dartmouth College, 2023 DNH 131 (D.N.H. 2023).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF NEW HAMPSHIRE

John Doe

v. Civil No. 22-cv-018-LM Opinion No. 2023 DNH 131 P Trustees of Dartmouth College

ORDER

Plaintiff John Doe—whom the court refers to using a pseudonym—brings this

action against the Trustees of Dartmouth College (“Dartmouth”) alleging that

Dartmouth violated Title IX of the Education Amendments of 1972 and committed

breach of contract in expelling Doe from Dartmouth’s Geisel School of Medicine

after Dartmouth determined that he sexually assaulted another medical student.

Presently before the court is Dartmouth’s motion to exclude Doe’s expert on lost

wages and lost earning capacity pursuant to Federal Rule of Evidence 702, Daubert

v. Merrell Dow Pharmaceuticals, Inc., and its progeny. See doc. no. 53. For the

following reasons, Dartmouth’s motion is granted in part and denied in part.

STANDARD OF REVIEW

Federal Rule of Evidence 702 is “[t]he touchstone for the admission of expert

testimony in federal court litigation . . . .” Crowe v. Marchand, 506 F.3d 13, 17 (1st

Cir. 2007). Under that rule, an expert witness may offer opinion testimony if:

(a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or 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 has reliably applied the principles and methods to the facts of the case.

Fed. R. Evid. 702 (effective until December 1, 2023).1 The proponent of the expert

opinion bears the burden of showing that it is admissible by a preponderance of the

evidence. See Martínez v. United States, 33 F.4th 20, 24 (1st Cir. 2022); United

States v. Tetioukhine, 725 F.3d 1, 6 (1st Cir. 2013); see also Fed. R. Evid. 702

advisory committee’s note to 2023 amendments (explaining that 2023 changes

“clarify and emphasize” that preponderance of the evidence standard applies).

The trial judge serves as a gatekeeper. Daubert v. Merrell Dow Pharm., Inc.,

509 U.S. 579, 597 (1993). When an adverse party lodges an objection to expert

testimony under Rule 702, the court must determine whether the testimony

satisfies the relevant foundational requirements. See id. “There is an important

difference between what is unreliable support and what a trier of fact may conclude

is insufficient support for an expert’s conclusion.” Milward v. Acuity Specialty

Prods. Grp., Inc., 639 F.3d 11, 22 (1st Cir. 2011) (emphasis omitted). “Vigorous

cross-examination, presentation of contrary evidence, and careful instruction on the

burden of proof are the traditional and appropriate means of attacking shaky but

admissible evidence.” Daubert, 509 U.S. at 596.

1 On December 1, 2023, among other changes, the present language of Rule

702(d) will be amended and replaced with: “the expert’s opinion reflects a reliable application of the principles and methods to the facts of the case.” This change “emphasize[s] that each expert opinion must stay within the bounds of what can be concluded from a reliable application of the expert’s basis and methodology,” but does not impose “any new, specific procedures.” Fed. R. Evid. 702 advisory committee’s note to 2023 amendments. The result here is the same regardless of whether the pre- or post-2023 amendment language is applied.

2 BACKGROUND2

The factual background of this case is discussed in the court’s order on

Dartmouth’s motion to dismiss. See doc. no. 42. It is unnecessary to fully recount

that background in resolving Dartmouth’s Daubert challenge. In short, Doe was a

fourth-year medical student at Geisel whom Dartmouth subjected to an internal

disciplinary proceeding after Doe’s former roommate, Sam Smith,3 alleged that Doe

performed oral sex on him without his consent. Dartmouth ultimately found,

pursuant to that proceeding, that Doe sexually assaulted Smith and expelled Doe

from Geisel. Doe thereafter brought this action for injunctive and monetary relief,

alleging that Dartmouth’s disciplinary proceeding failed to abide by the strictures of

Title IX as well as its own policies, which Doe contends is a breach of contract.

Dartmouth now seeks to prohibit Doe’s expert on lost wages and lost earning

capacity—Cyndi Livermore, former Director of ComStock Valuation Advisors, Inc.

—from offering expert opinion testimony. Dartmouth attached a copy of Livermore’s

report to its motion to preclude her from testifying. See doc. no. 54-1. Livermore’s

report analyzes Doe’s lost wages and lost earning capacity as a result of his

2 It does not appear that either party requested a hearing—evidentiary or

otherwise—on Dartmouth’s motion. See doc. no. 53 at 6; doc. no. 58 at 7. There is no mandatory procedure for addressing Daubert motions. The First Circuit has held that a hearing is not required to determine the reliability of a proffered expert opinion so long as no novel issue is raised. See González-Arroyo v. Drs.’ Ctr. Hosp. Bayamón, Inc., 54 F.4th 7, 15 (1st Cir. 2022). As Dartmouth’s motion presents no novel issue, and because neither party requested a hearing, the court did not deem a hearing necessary.

3 As with Doe, the court refers to Smith using a pseudonym.

3 expulsion based on two potential career paths: internal medicine and cardiology.4

She ultimately determined that Doe has already suffered damages in the form of

lost wages in an amount of at least $429,000 (if he pursued internal medicine) and

up to $784,000 (if he pursued cardiology). She further concluded that Doe’s future

lost earnings will total between $1.52 million (as a practitioner of internal medicine)

and $3.97 million (as a cardiologist).

To arrive at these figures, Livermore considered: (1) an estimation of Doe’s

remaining work life; (2) Doe’s anticipated life expectancy; (3) the probability of

employment in each career path; and (4) Doe’s projected earnings for each career

path but-for his expulsion. To determine his but-for earnings, Livermore considered:

(a) Doe’s earnings prior to his expulsion from Dartmouth; (b) the probability,

expectancy, and reasonability of future earnings; and (c) future growth. In addition,

Livermore considered Doe’s post-expulsion income and projections of actual or

mitigated earnings.

DISCUSSION

Dartmouth makes four arguments to exclude Livermore’s testimony. First,

Dartmouth argues that Livermore lacks the requisite technical or specialized

knowledge to testify as an expert regarding lost wages or lost earning capacity.

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2023 DNH 131, Counsel Stack Legal Research, https://law.counselstack.com/opinion/john-doe-v-p-trustees-of-dartmouth-college-nhd-2023.