Thacker v. Ethicon, Inc.

District Court, E.D. Kentucky·Decided July 21, 2025·No. 5:20-cv-00050·Unknown

Opinion

UNITED STATES DISTRICT COURT EASTERN DISTRICT OF KENTUCKY CENTRAL DIVISION LEXINGTON

CONNIE J. THACKER, CIVIL ACTION NO. 5:20-cv-50-KKC Plaintiff, V. OPINION & ORDER ETHICON INC., et al., Defendants. *** *** *** This matter is before the Court on the Defendants’ motion to exclude or limit certain opinions and testimony of plaintiff Connie Thacker’s expert, Anne Wilson, MBA. (DE 163.) I. Factual Background The factual background for this matter is set forth in detail in the Court’s opinion and order entered on July 8, 2025. (DE 307.) This opinion addresses the Defendants’ motion asking the Court to preclude plaintiff expert Anne Wilson from offering testimony on certain subjects. Wilson is a biomedical engineer and quality assurance consultant, holding certifications as a Quality Auditor and Quality Engineer. Wilson has been designated as an expert in the field of compliance with quality and risk management standards. She is expected to testify that Ethicon failed to meet the “industry standards” for design control processes and risk management. II. Analysis Under Federal Rules of Evidence 702, an expert witness may testify if (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; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; (d) the expert has reliably applied the principles and methods to the facts of the case.

Fed. R. Evid. 702(a)–(d). A court is charged with a “gatekeeping function” to ensure expert testimony is both reliable and relevant. Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 597 (1993). The test for determining reliability is flexible and can adapt to the particular circumstances underlying the testimony at issue. Kumho Tire Co. v. Carmichael, 526 U.S. 137, 150-51 (1999). The Defendants argue that Wilson’s testimony should be (1) excluded entirely because it is unreliable, or (2) limited on certain subjects. a. Reliability of Wilson’s testimony

The Defendants argue that Wilson’s testimony should be excluded entirely because it is unreliable. Namely, the Defendants take issue with Wilson’s methodology. The Supreme Court has said that “[t]he objective of [the Daubert gatekeeping] requirement . . . is to make certain that an expert, whether basing testimony upon professional studies or personal experience, employs in the courtroom the same level of intellectual rigor that characterizes the practice of an expert in the relevant field.” Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137, 152 (1999). As a result, Daubert and its progeny require experts to base their opinions on sufficient methodologies to render their testimony reliable. The Defendants argue that Wilson’s methodology is insufficient because she (1) should have conducted an audit of Ethicon’s systems; (2) failed to consider applicable U.S. standards while inappropriately basing her “industry standards” testimony on inapplicable European standards; and (3) failed to review all relevant case materials in reaching her conclusions. i. Failure to audit

Wilson did not have to conduct an audit of Ethicon’s systems—as the Defendants suggest—to render her methodology reliable. As Wilson explains in her report, her role in this case involves “address[ing] the design control and risk management processes of Ethicon[.]” (DE 163-1 at Page ID# 4081.) One method that could be used to address such processes is an audit. But the Defendants do not explain, or offer any authority to explain, how conducting an audit is the only reliable methodology available for reviewing the processes Wilson has been asked to review. To the contrary, the methodology Wilson used to arrive at her opinions, which involved reviewing Ethicon’s design and risk control documents and evaluating them within the framework of industry standards, is plainly based on “sufficient facts,” and “reliable principles and methods.” Fed. R. Evid. 702; In re Scrap Metal

Antitrust Litig., 527 F.3d 517, 530 (6th Cir. 2008) (“Where an expert’s testimony amounts to ‘mere guess or speculation,’ the court should exclude his testimony, but where the opinion has a factual basis, it should not be excluded [because] it is up to opposing counsel to inquire into the expert’s factual basis.”). ii. Failure to review appropriate industry standards

The Court will now turn its attention to the Defendants’ chief objection to Wilson’s testimony—that being the contention that her testimony on “industry standards” is based on wrong or incomplete standards. The Defendants argue that (1) Wilson should not have consulted standards set by the International Organization for Standardization; and (2) she should have consulted applicable FDA regulations in offering testimony on Ethicon’s compliance with “industry standards.” Essentially, the Defendants argue that Wilson’s testimony is unreliable because she bases her “industry standards” testimony on an incomplete picture of what makes up the universe of “industry standards” for her field of expertise. As explained below, however, this is incorrect, and Wilson’s testimony is not based on an unreliable methodology. No party disputes that particular FDA regulations make up a portion of the universe of “industry standards” for design control and risk management processes in the medical device manufacturing industry. The Defendants argue that standards set by the International Organization for Standardization (which are referred to as “ISOs”), however, are not a part of that same universe. (DE 163 at 6.) Wilson’s report states the opposite— explaining that ISOs were “[t]he primary standards applicable” to Ethicon’s quality and risk management systems at the time Ethicon developed the at-issue devices. (DE 163-1 at Page ID# 4083.) She also explained during her deposition that applicable ISOs and FDA regulations are very similar. (DE 163-2, Wilson Depo., at Page ID# 4111.) To the extent that the Defendants have evidence to refute Wilson’s conclusion that

ISOs were “[t]he primary standards applicable,” they may confront her with it through “vigorous cross-examination,” at trial. But the Defendants objection is not sufficient to render her testimony unreliable at this stage. Daubert, 509 U.S. at 596. This conclusion is reinforced by the Defendants failure to offer any evidence or authority stating that ISOs are irrelevant to medical device manufacturers in the United States. Contra Cisson v. C.R. Bard, Inc., No. 2:11-cv-00195 2013 U.S. Dist. LEXIS 149976, at *36 (S.D. W.V. Oct. 18, 2013) (“evidence of [a manufacturer’s] compliance with ISO standards is relevant.”). Moreover, Wilson’s failure to consider applicable FDA regulations during her review of this case does not render her testimony unreliable. To be clear, Wilson admits that she did not consider applicable FDA regulations and rather only considered applicable ISOs.1 But this failure does not, in and of itself, render her methodology and testimony unreliable. This is because Wilson plainly opines that ISOs were “[t]he primary standards applicable” to Ethicon’s quality and risk management systems.

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Thacker v. Ethicon, Inc., (E.D. Ky. 2025).

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