Lawes v. CSA Architects and Engineers

Summary

The First Circuit reviewed a negligence action arising from a pedestrian's injury in a construction-affected area in San Juan, Puerto Rico. The district court excluded the plaintiff's expert testimony under Federal Rules of Civil Procedure 26 and Federal Rule of Evidence 702 and then entered judgment as a matter of law for the defendants. The First Circuit held that the district court erred, vacated the dismissal, and remanded for further proceedings.

Holdings

1. The district court abused its discretion by imposing the case-dispositive sanction of excluding Lawes's sole expert witness under Rules 26 and 37(c)(1). Although Lawes's disclosures were deficient, the record did not establish the degree of surprise or prejudice necessary to justify preclusion.
2. The district court abused its discretion by excluding Aronberg's traffic-engineering opinions under Rule 702. His opinions were sufficiently supported by facts and data, employed a reliable methodology, and reliably applied that methodology to the case; alleged weaknesses generally went to weight and credibility rather than admissibility.
3. The judgment as a matter of law was vacated because it followed from the erroneous exclusion of Lawes's only expert witness. The court did not decide the merits of the Rule 50 ruling.

Questions Presented

1. Whether the district court abused its discretion by excluding Lawes's expert testimony as a sanction for violations of Federal Rule of Civil Procedure 26 and Rule 37(c)(1).
2. Whether the district court abused its discretion by excluding Aronberg's testimony under Federal Rule of Evidence 702 and Daubert.
3. Whether the district court's resulting judgment as a matter of law should stand.

Disposition

reversed_and_remanded