Minden v. Allstate Property and Casualty Insurance Company

CourtDistrict Court, D. Nevada
DecidedApril 4, 2024
Docket2:21-cv-00151
StatusUnknown

This text of Minden v. Allstate Property and Casualty Insurance Company (Minden v. Allstate Property and Casualty Insurance Company) is published on Counsel Stack Legal Research, covering District Court, D. Nevada primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Minden v. Allstate Property and Casualty Insurance Company, (D. Nev. 2024).

Opinion

1 UNITED STATES DISTRICT COURT 2 DISTRICT OF NEVADA 3 MICHAEL MINDEN and THERESA Case No.: 2:21-cv-00151-APG-BNW MINDEN, 4 Order Denying Motion to Strike and Plaintiffs Related Motion in Limine 5 v. [ECF Nos. 103, 133] 6 ALLSTATE PROPERTY AND CASUALTY 7 INSURANCE COMPANY,

8 Defendant

9 Defendant Allstate Property and Casualty Insurance Company moves to strike the 10 plaintiffs’ expert witness, Marcor G. Platt. ECF No. 103. Allstate filed a duplicate motion in 11 limine to exclude Platt from testifying at trial. ECF No. 133. 12 The parties are familiar with the facts, so I repeat them here only as necessary to decide 13 the motions. I deny the motions because the arguments Allstate raise are matters for cross 14 examination and are not bases to strike Platt’s testimony. 15 I. ANALYSIS 16 Federal Rule of Evidence 702 governs the admissibility of Platt’s opinions. Under Rule 17 702, a witness “who is qualified as an expert by knowledge, skill, experience, training, or 18 education may testify in the form of an opinion or otherwise if . . . : 19 (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; 20 (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and 21 (d) the expert has reliably applied the principles and methods to the facts of the case. 22

23 1 To be admissible, expert testimony thus must be both relevant and reliable. “Expert opinion 2 testimony is relevant if the knowledge underlying it has a valid connection to the pertinent 3 inquiry. And it is reliable if the knowledge underlying it has a reliable basis in the knowledge 4 and experience of the relevant discipline.” Primiano v. Cook, 598 F.3d 558, 565 (9th Cir. 2010), 5 as amended (Apr. 27, 2010). Where there is a sufficient foundation for the testimony, it is up to

6 the jury to evaluate the expert’s credibility. Id. at 565-66. 7 Rule 702’s inquiry is “flexible,” and should be applied in favor of admitting the evidence. 8 Wendell v. GlaxoSmithKline LLC, 858 F.3d 1227, 1232 (9th Cir. 2017) (quotation omitted). 9 “Shaky but admissible evidence is to be attacked by cross examination, contrary evidence, and 10 attention to the burden of proof, not exclusion.” Primiano, 598 F.3d at 564. 11 A. Opinions Based on Relevant Facts and Data 12 Allstate argues that Platt’s testimony is not helpful to the jury, does not rely on relevant 13 facts or data, and is speculative because Platt did not examine the original roof after the alleged 14 wind incident took place in September 2019. Rather, Platt examined the roof in August 2021,

15 after a new roof had been installed. Allstate also argues that the tiles Platt took for testing were 16 not in their original locations because a roofing company moved them during the roof 17 replacement in 2020. And it argues that any displaced tiles Platt observed in 2021 were 18 unrelated to the wind event in 2019 because the roof was replaced in 2020. Allstate argues that 19 Platt’s opinions are based on other experts’ reports and interviews, so his “opinions are nothing 20 more than a comparison of the evidence provided by others.” ECF No. 103 at 10. 21 The Mindens respond that Platt reviewed photographs of the original roof as well as 22 conducted his own observations, tests, and calculations. They contend that as an expert, he is 23 allowed to offer opinions based on facts or data that he has not personally observed. The 1 Mindens argue that the tiles Platt tested were original roof tiles because the new roof included 2 some original tiles, so the fact that the roof was replaced in 2020 does not negate his results. 3 They contend that if the new roof was susceptible to wind damage, so was the old one, so his 4 observations in 2021 are not irrelevant or speculative. 5 1. Relying on Others’ Reports

6 Platt interviewed the Mindens, the contractor who replaced the roof, and a neighbor who 7 experienced wind damage to her roof. ECF No. 103-1 at 5, 9-10. He reviewed documentation, 8 photographs, and reports prepared by others. Id. at 7. Platt also conducted two site visits to the 9 Minden residence, conducted weather research, removed tile samples and sent them to a lab for 10 testing, and performed calculations regarding maximum probable wind speed and how that may 11 have impacted the tiles on the roof. Id. at 4, 8-9; ECF No. 103-5 at 7. Thus, Platt relied on 12 information obtained from others, as well as his own observations and calculations, to reach his 13 opinions. Doing so does not make his opinions inadmissible. See Daubert v. Merrell Dow 14 Pharms., Inc., 509 U.S. 579, 592 (1993) (stating that “an expert is permitted wide latitude to

15 offer opinions, including those that are not based on firsthand knowledge or observation”); 16 Carson Harbor Vill., Ltd. v. Unocal Corp., 270 F.3d 863, 873 (9th Cir. 2001) (noting that 17 “experts are entitled to rely on hearsay in forming their opinions” so long as “the underlying 18 facts or data are of a type reasonably relied upon by experts in the particular field in forming 19 opinions or inferences upon the subject” (simplified)). Allstate has not suggested that experts in 20 Platt’s field would not have relied on interviews, photographs, or other secondhand sources that 21 Platt relied on. Indeed, Allstate’s expert likewise did not view the roof before its replacement 22 23 1 and similarly relied on photographs of the old roof and information provided by the Mindens.1 2 See ECF No. 111 at 167, 173-74, 182. Thus, it appears that experts in the field would rely on the 3 same or similar materials as Platt did, and Allstate has not shown otherwise. I therefore deny 4 this portion of Allstate’s motion. 5 2. Replacement Roof

6 When the roof was replaced, the roofer used the original tiles if they were not damaged. 7 ECF Nos. 103-1 at 9; 103-2 at 13. Platt opined that the tiles he sent for testing were the original 8 roof tiles, not replacements. ECF Nos. 103-1 at 4, 32; 103-5 at 9. Consequently, the jury could 9 find that the testing performed on those tiles would be consistent with testing done on the 10 original roof tiles. Whether the tested tiles were original tiles, whether they were in a different 11 location after the roof replacement, and how the tiles were stored or transported to the testing site 12 are matters for cross examination, not exclusion. 13 3. Displaced Tiles in 2021 14 During his site visits in 2021, Platt observed displaced and cracked roof tiles. ECF No.

15 103-1 at 10-11. Those tiles would not have been disturbed by a 2019 wind event because the 16 roof was replaced in 2020. But Platt does not opine that the tiles he observed were displaced by 17 the 2019 event. Rather, he notes that, like the original tiles, the current roof tiles “are susceptible 18 to displacement under the windspeeds which occur at the property.” Id. at 33. Because this 19 information is relevant to the question of whether wind gusts at the proper speed could displace 20 roof tiles and Allstate has not explained why that conclusion is not reliable, there is no basis to 21 exclude his testimony. Consequently, I deny this portion of Allstate’s motion. 22

1 The Mindens argue that Allstate’s expert’s opinions should be excluded. ECF No. 110 at 19-23. 23 But the Mindens have not moved to exclude Allstate’s expert.

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Related

Primiano v. Cook
598 F.3d 558 (Ninth Circuit, 2010)
Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
Carson Harbor Village, Ltd. v. Unocal Corporation
270 F.3d 863 (Ninth Circuit, 2001)
Stephen Wendell v. Glaxosmithkline LLC
858 F.3d 1227 (Ninth Circuit, 2017)

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Minden v. Allstate Property and Casualty Insurance Company, Counsel Stack Legal Research, https://law.counselstack.com/opinion/minden-v-allstate-property-and-casualty-insurance-company-nvd-2024.