Schwab v. Nissan North America, Inc.

502 F. Supp. 2d 980, 74 Fed. R. Serv. 639, 2007 U.S. Dist. LEXIS 41832, 2007 WL 1691947
CourtDistrict Court, E.D. Missouri
DecidedJune 8, 2007
Docket1:04CV00025 RWS
StatusPublished

This text of 502 F. Supp. 2d 980 (Schwab v. Nissan North America, Inc.) is published on Counsel Stack Legal Research, covering District Court, E.D. Missouri primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Schwab v. Nissan North America, Inc., 502 F. Supp. 2d 980, 74 Fed. R. Serv. 639, 2007 U.S. Dist. LEXIS 41832, 2007 WL 1691947 (E.D. Mo. 2007).

Opinion

502 F.Supp.2d 980 (2007)

Carl Tracy SCHWAB, et al., Plaintiffs,
v.
NISSAN NORTH AMERICA, INC., et al., Defendants.

No. 1:04CV00025 RWS.

United States District Court, E.D. Missouri, Southeastern Division.

June 8, 2007.

*981 James P. Lambert, James P. Lambert, ALC, Lafayette, LA, Mary L. Wolff, Michael A. Chovanec, Patrick M. Ardis, Wolff and Ardis, Memphis, TN, Joseph P. Rice, III, Rice and Spaeth, Cape Girardeau, MO, for Plaintiffs.

David W. Graves, Jr., Kim M. Schmid, Nathan H. Bjerke, Ryan L. Nilsen, Bowman and Brooke, Minneapolis, MN, Mark V. Berry, Bowman and Brooke LLP, Gardena, CA, Thomas M. Klein, Bowman and Brooke LLP, Reed W. Sugg, Sandberg and Phoenix, Phoenix, AZ, Todd C. Stanton, Sandberg Phoenix, P.C., St. Louis, Mo, Brent J. Burtin, Law Offices of Marshall R. Hoekel, P.C., Webster Groves, MO, for Defendants.

MEMORANDUM AND ORDER

SIPPEL, District Judge.

This is a product liability case arising out of a rollover crash of a 2002 Nissan Xterra vehicle. Plaintiffs have identified three experts to offer opinions regarding the alleged propensity of the 2002 Nissan Xterra roof to collapse during foreseeable rollover accidents. Plaintiffs' experts conducted two tests: A two-sided roof strength test and a Jordan Rollover System ("JRS")test.

The Nissan defendants[1] have moved to exclude evidence of both the two-sided test and the JRS test and any opinions based on these tests pursuant to Rule 702 of the Federal rules of Evidence.

*982 The Nissan defendants argue that the two-sided test should be excluded under Rule 702 because the test:

• incorporates parameters arbitrarily selected by plaintiffs' experts;
• has not been validated against real world data;
• has not been subjected to meaningful peer review or publication; and
• is not generally accepted in the filed of automotive engineering.

The Nissan defendants argue that the JRS test should be excluded under Rule 702 because the test:

• is unreliable in its design;
• lacks validation and a well defined pass fail criteria;
• was unreliable in its execution;
• has not been subjected to meaningful peer review or publication; and
• is not generally accepted in the field of automotive engineering.

I held four days of hearings on these issues. Oral argument and evidence was presented by the parties on October 23, 2006, February 7, 2007, March 14, 2007 and May 11, 2007.

Based on the evidence and argument presented at the hearings, I find that the two-sided test and the JRS test should be excluded pursuant to Federal Rule of Evidence 702.

BACKGROUND

Carl Schwab was driving a 2002 Nissan Xterra on December 24, 2002. The car left the roadway and rolled over. Mr. Schwab sustained severe injuries in the rollover accident. His complaint alleges state law product liability, negligence and breach of warranty claims based on an alleged propensity of the 2002 Nissan Xterra's roof to collapse during foreseeable rollovers.

Plaintiffs have retained Donald Friedman, Dr. Jack Bish and Dr. George Rechnitzer to conduct tests and offer opinions in support of plaintiffs' claims. The Nissan defendants do not challenge the credentials of the plaintiffs' experts. The Nissan defendants challenge the tests conducted by plaintiffs' experts and their resulting opinions based on these tests.

STANDARD FOR ADMISSIBILITY OF EXPERT TESTIMONY

Federal Rule of Evidence 702 provides that if expert testimony "will assist the trier of fact to understand the evidence or to determine a fact in issue" an expert may testify where "(1) the testimony is based upon sufficient facts or data, (2) the testimony is the product of reliable principles and methods, and (3) the witness has applied the principles and methods reliably to the facts of the case."

Trial courts serve as gate keeper to "ensure that any and all scientific testimony or evidence admitted is not only relevant, but reliable." See Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 589, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993); see also Kumho Tire Co. v. Carmichael, 526 U.S. 137, 141, 119 S.Ct. 1167, 143 L.Ed.2d 238 (1999) ("We conclude that Daubert's general holding — setting forth the trial judge's `gatekeeping' obligation — applies not only to [expert] testimony based on `scientific' knowledge, but also to [expert] testimony based on `technical' or `other specialized' knowledge.") In exercising the gatekeeper function, the trial court' must just make a "preliminary assessment of whether the reasoning or methodology . . . properly can be applied to the facts in issue," focusing specifically on the methodology and not the conclusion. See Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 593, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993)

The starting point for an examination of any expert testimony is in the nonexclusive list of factors set forth in Daubert:

*983 (1) whether the theory or technique can be and 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 in using a particular scientific technique and the existence and maintenance of standards controlling the technique's operation; and
(4) whether the theory or technique has been generally accepted in the particular field.

Daubert, 509 U.S. at 593-94, 113 S.Ct. at 2796-97.

TWO-SIDED TEST ANALYSIS

A. Description of the Two-sided Test.

The two-sided test conducted by plaintiffs' experts uses a hydraulic ram to press a flat 12 inch by 24 inch steel plate, or "platen," against a stationary vehicle's roof. A platen is first applied to the front edge of the roof on the driver's side at an angle of 25 degrees from vertical. The platen is pushed against the roof long enough and hard enough to crush it five inches. Instruments record the force applied to the roof during the test. The process is then repeated on the passenger side of the vehicle, except that the platen is applied at an angle of 40 degrees from vertical, rather than 25 degrees.

The two-sided test has similarities to the federally approved Federal Motor Vehicle Safety Standard (FMVSS) 216 Test.[2] However, as discussed below, the two-sided test deviates significantly from the FMVSS 216 test.

B. The two-sided test incorporates arbitrary parameters.

Based on the evidence and argument during the four days of hearings, I find that Plaintiffs failed to establish that the *984 parameters of the two-sided test are an appropriate method for testing roof strength.

The federally approved FMVSS 216 test uses a plate that is 30 inches by 72 inches in size.

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Related

Daubert v. Merrell Dow Pharmaceuticals, Inc.
509 U.S. 579 (Supreme Court, 1993)
General Electric Co. v. Joiner
522 U.S. 136 (Supreme Court, 1997)
Kumho Tire Co. v. Carmichael
526 U.S. 137 (Supreme Court, 1999)

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502 F. Supp. 2d 980, 74 Fed. R. Serv. 639, 2007 U.S. Dist. LEXIS 41832, 2007 WL 1691947, Counsel Stack Legal Research, https://law.counselstack.com/opinion/schwab-v-nissan-north-america-inc-moed-2007.