Richard Lee Mullenhour, Estate Plaintiff, v. Penn Central Corporation, et al., Defendants.

District Court, N.D. Indiana·Decided September 11, 2026·No. 3:22-cv-00032·Unknown

Opinion

UNITED STATES DISTRICT COURT NORTHERN DISTRICT OF INDIANA SOUTH BEND DIVISION

RICHARD LEE MULLENHOUR,

Estate Plaintiff,

v. Case No. 3:22-CV-32-CCB

PENN CENTRAL CORPORATION, et al.,

Defendants.

OPINION AND ORDER In anticipation of trial, Defendants have moved to exclude the testimony of Plaintiff’s expert Dr. Mark Levin. (ECF 139). Plaintiff has made a reciprocal motion to exclude the testimony of Defendants’ expert Dr. Peter G. Shields. (ECF 141). The Court now rules on both motions. STANDARD Expert testimony is admissible at trial under Federal Rule of Evidence 702 if the testimony is relevant to a fact in issue, is based on sufficient facts or data, and results from reliable scientific or other expert methods that are properly applied. Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 592–93 (1993). Before admitting expert testimony, courts “must determine whether the witness is qualified; whether the expert's methodology is scientifically reliable; and whether the testimony will assist the trier of fact to understand the evidence or to determine a fact in issue.” Gopalratnam v. Hewlett-Packard Co., 877 F.3d 771, 779 (7th Cir. 2017) (internal quotations omitted). As the 2023 Amendment to Rule 702 clarified, courts have an independent gatekeeping duty to ensure the reliability of experts by a preponderance of the evidence. Fed. R.

Evid. 702 advisory committee’s note to 2023 amendment, n.1.1 In making this determination, courts often look to factors such as whether a theory has been subjected to peer review or accepted within the relevant expert community, whether there are standards controlling the technique’s operation, and whether it has a potential error rate. See Deputy v. Lehman Bros., 345 F.3d 494, 505 (7th Cir. 2003). Still, “No one factor is dispositive . . . and ‘the Supreme Court has repeatedly emphasized [that] the Rule 702

test is a flexible one.’ ” Timm v. Goodyear Dunlop Tires N. Am., Ltd., 932 F.3d 986, 993 (7th Cir. 2019) (alteration in original) (quoting Smith v. Ford Motor Co., 215 F.3d 713, 719 (7th Cir. 2000)). In addition, “the correct inquiry focuses not on ‘the ultimate correctness of the expert's conclusions,’ but rather on ‘the soundness and care with which the expert arrived at her opinion.’” Id. (quoting Schultz v. Akzo Nobel Paints, LLC, 721 F.3d 426, 431

(7th Cir. 2013)). An expert’s opinion “must consist of more than simply ‘subjective belief or unsupported speculation.’” Cummins v. Lyle Indus., 93 F.3d 362, 368 (7th Cir. 1996) (citing Daubert, 509 U.S. at 589). The burden to establish the admissibility of an expert's

1 Thus, any caselaw before or after the 2023 amendment holding that expert reliability is a question of weight for the jury would be invalid. See Delaware v. Pennsylvania, 598 U.S. 115, 120 (2023) (changes in the relevant law can abrogate precedent); United States v. Mitan, 966 F.2d 1165, 1170 (7th Cir. 1992) (“The rules of evidence are not advisory—they are obligatory”). At the same time, the amendments to Rule 702 were clear that they did not change the Rule’s meaning, but merely clarified its application. See Fed. R. Evid. 702 2023 comments, at n. 2 (“Nothing in the amendment imposes any new, specific procedures”). Any circuit caselaw that properly interpreted and applied Rule 702 prior to the 2023 amendment would be as equally binding on this Court after the amendment as before it. See In re Abbott Lab'ys, et al., Preterm Infant Nutrition Prods. Liab. Litig., No. 22 C 00071, 2025 WL 2987083, at *4 (N.D. Ill. Oct. 23, 2025) testimony by a preponderance of the evidence falls on its proponent. Varlen Corp. v. Liberty Mut. Ins., 924 F.3d 456, 459 (7th Cir. 2019).

Under Rule 702, an expert may be qualified to testify by “knowledge, skill, experience, training, or education.” Higgins v. Koch Dev. Corp., 997 F. Supp. 2d 924, 930 (S.D. Ind. 2014) (quoting Fed. R. Evid. 702). An expert is qualified if his “qualifications provide a foundation for [him] to answer a specific question.” Id. (quoting Berry v. City of Detroit, 25 F.3d 1342, 1351 (6th Cir. 1994)). In other words, courts determine whether an expert is qualified by evaluating each of the expert's conclusions individually, then

assessing whether the expert has the “adequate education, skill, and training to reach them.” Gayton v. McCoy, 593 F.3d 610, 617 (7th Cir. 2010). An expert's specialization, or lack thereof, “typically goes to the weight to be placed on [her] opinion, not its admissibility.” Hall v. Flannery, 840 F.3d 922, 929 (7th Cir. 2016). In toxic torts cases like the one here, plaintiffs usually must provide testimony on

both “general causation” and “specific causation.” General causation establishes the ability of a substance to cause or contribute to a disease under certain conditions, while specific causation establishes that a plaintiff’s actual exposure did in fact contribute to a disease. See Hammer v. Residential Credit Sols., Inc., No. 13 C 6397, 2015 WL 7776807, at *37 (N.D. Ill. Dec. 3, 2015) (citing Myers v. Illinois Cent. R. Co., 629 F.3d 639, 641–42 (7th

Cir. 2010)). ANALYSIS A. Defendants’ Motion to Exclude Plaintiff brings Dr. Levin to testify on both general and specific causation with regard to welding fume exposure. See supra page 3. Defendants have moved to exclude

Dr. Levin, arguing that his methodology is flawed. First, Defendants argue that Dr. Levin’s process for researching and arriving at his general causation opinion on welding fume exposure was not reliable. Second, they object to a portion of Dr. Levin’s testimony on specific causation, arguing that he had no basis to claim that exposure to any welding fume levels “above background” could have contributed to Plaintiff’s cancer. Third, they object to the entirety of Dr. Levin’s specific causation opinion on the

basis that he used an unreliable source for his facts and data. 1. General Causation Opinion Dr. Levin’s general causation opinion heavily relies on work by the International Agency of Research on Cancer (“IARC”), which found that certain levels of exposures to welding fumes could increase the risk of lung cancer. (ECF 148-1 at 12–14).

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Richard Lee Mullenhour, Estate Plaintiff, v. Penn Central Corporation, et al., Defendants., (N.D. Ind. 2026).

Richard Lee Mullenhour, Estate Plaintiff, v. Penn Central Corporation, et al., Defendants. (Richard Lee Mullenhour, Estate Plaintiff, v. Penn Central Corporation, et al., Defendants.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

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