Valentine v. Pioneer Chlor Alkali Co., Inc.

921 F. Supp. 666, 1996 U.S. Dist. LEXIS 5252, 1996 WL 161673
CourtDistrict Court, D. Nevada
DecidedMarch 29, 1996
DocketCV-S-92-887-ECR, CV-S-93-0475-ECR, and CV-S-93-0476-ECR
StatusPublished
Cited by13 cases

This text of 921 F. Supp. 666 (Valentine v. Pioneer Chlor Alkali Co., Inc.) 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
Valentine v. Pioneer Chlor Alkali Co., Inc., 921 F. Supp. 666, 1996 U.S. Dist. LEXIS 5252, 1996 WL 161673 (D. Nev. 1996).

Opinion

ORDER

EDWARD C. REED, Jr., District Judge.

About an hour after midnight on May 6, 1991, a pipe connected to a storage tank at Defendant Pioneer Chlor Alkali Company’s chemical manufacturing facility at Henderson, Nevada ruptured, allowing the contents of the tank to escape into the atmosphere. The tank had been used to store liquid chlorine, and the rupture of the pipe created a cloud of chlorine vapor which hung in the air and began to invade the homes and bodies of the town’s inhabitants.

This case arises out of that accidental release of chlorine into the air in Henderson. The plaintiffs 1 are three Henderson residents who claim that inhaling chlorine has damaged not only their lungs but their brains and nervous systems as well. Plaintiffs and their counsel have enlisted the help of several doctors, whom they have proposed to call to give sworn testimony as to the observed effects of chlorine gas exposure on their neurological and emotional health. Defendant

*669 Pioneer Chlor Alkali Company has moved this court for an order barring Plaintiffs’ experts from offering their medical opinions as expert scientific evidence. Defendant’s Motions in Limine (Doe. # 125 in Case No. 92-0887; Doc. # 122 in Case No. 93-0475).

I. Daubert and the Law of Scientific Evidence

Lawyers, judges and juries are not usually trained in science or medicine, hence the need for the testimony of true experts in cases such as this where the plaintiffs claim a causal relation between the act or omission of the defendant and the subsequent appearance of disease in the plaintiffs. The drafters of the Federal Rules of Evidence' hoped to give the federal courts some guidance in deciding when such expert testimony is ap-' propriate, and in deciding what types of testimony legitimately qualify as science. Fed.R.Evid. 702.

A. Daubert: The Supreme Court Opinion

In 1993 the United States Supreme Court interpreted Evidence Rule 702 as superseding the traditional rule, announced in Frye v. United States, 293 F. 1013 (D.C.Cir.1923); see also United States v. Solomon, 753 F.2d 1522, 1526 (9th Cir.1985), which required the proponent of expert scientific testimony to show that the conclusions advanced by the proposed witness were generally accepted in the relevant scientific community. Frye was a relatively straightforward test. Litigants bolstered their proposed expert testimony with meta-evidence on the probity of the proposed testimony to scientific facts, and the court exercised its judgment with the aid of scientific consensus. Frye was the law for most of the twentieth century. In 1993 the Supreme Court wiped the slate clean.

The scientific facts to which an expert testifies need no longer achieve general acceptance in the scientific community to be admissible in federal court; rather, the proponent need only demonstrate that the investigatory methods employed by the proposed expert witness consist with generally accepted methods of scientific investigation. Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993) (“Daubert”).

Where the opponent of the proposed expert scientific testimony moves in limine against the admission of that science in evidence, the district court must determine whether the proposed testimony reflects “scientific knowledge,” i.e. whether the proposed expert has arrived at her findings via the “scientific method.” Put in shorthand form, the inquiry on a motion in limine is whether the expert has done “good science.” Daubert v. Merrell Dow Pharm., Inc., 43 F.3d 1311, 1315 (9th Cir.1995), on remand from 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469 (1993) (“Daubert II ”), cert. denied,— U.S.-, 116 S.Ct. 189, 133 L.Ed.2d 126 (1995).

Plainly, the qualification of the proposed witness as an expert in the relevant field by no means disposes of the question whether the findings to which she will testify constitute “scientific knowledge.” Daubert II, 43 F.3d at 1319. But neither does Daubert require that the accuracy of the proposed scientific evidence be established with absolute certainty. Daubert II, 43 F.3d at 1316. The key inquiry, in fact, does not concern the substantive “truth” of the proposed evidence at all, but rather focuses on the methodological basis of that evidence. Daubert II, 43 F.3d at 1316.

Thus, the essence of Daubert is the requirement that the district court be satisfied with the process employed by the proposed expert in obtaining her results. That said, Daubert offers comparatively little guidance with respect to the precise standards the district judge must apply to the proposed evidence before ruling on its admissibility.

B. Daubert II: The Ninth Circuit Opinion

The Ninth Circuit’s decision on remand in Daubert itself began its attempt to apply the decision of the Supreme Court -with the observation that the expert’s self-serving assurance to the court of the integrity of her methodology would not satisfy Fed.R.Evid. 702. Daubert II, 43 F.3d at 1316. The Court of Appeals recognized that under the new rule, the proponent of expert scientific *670 evidence must show that its expert witness’s findings are grounded in sound science, and further recognized that that showing necessarily entails some independent indication that the expert’s methodology was scientifically sound. Id. at 1316.

Judge KozinskL’s opinion in Daubert II enumerated several factors to be used in determining the admissibility of expert scientific evidence: (1) whether the methods employed by the proposed witness have achieved “general acceptance” in the scientific community; (2) the extent to which the proposed scientific findings have been subjected to “peer review” and/or been published in a scientific journal; (3) the degree to which those findings are capable of empirical verification; and (4) whether the findings’ margin of error lies within acceptable limits. The Daubert II court emphasized that this list of factors is by no means exhaustive, but only illustrative. 43 F.3d at 1316-17.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Elher v. Misra
870 N.W.2d 335 (Michigan Court of Appeals, 2014)
Paulette Elher v. Dwijen Misra Jr Md
Michigan Court of Appeals, 2014
Hallmark v. Eldridge
189 P.3d 646 (Nevada Supreme Court, 2008)
In Re Omeprazole Patent Litigation
490 F. Supp. 2d 381 (S.D. New York, 2007)
AstraZeneca AB v. Mylan Laboratories Inc.
490 F. Supp. 2d 381 (S.D. New York, 2007)
Wallace v. Simpson Pasadena Paper Co.
152 S.W.3d 688 (Court of Appeals of Texas, 2004)
Astra Aktiebolag v. Andrx Pharmaceuticals, Inc.
222 F. Supp. 2d 423 (S.D. New York, 2002)
Downs v. Perstorp Components, Inc.
126 F. Supp. 2d 1090 (E.D. Tennessee, 1999)
Pick v. American Medical Systems, Inc.
958 F. Supp. 1151 (E.D. Louisiana, 1997)
National Bank of Commerce v. Dow Chemical Co.
965 F. Supp. 1490 (E.D. Arkansas, 1996)
Sanderson v. International Flavors & Fragrancies, Inc.
950 F. Supp. 981 (C.D. California, 1996)

Cite This Page — Counsel Stack

Bluebook (online)
921 F. Supp. 666, 1996 U.S. Dist. LEXIS 5252, 1996 WL 161673, Counsel Stack Legal Research, https://law.counselstack.com/opinion/valentine-v-pioneer-chlor-alkali-co-inc-nvd-1996.