Varlen Corporation v. Liberty Mutual Insurance Company

Summary

Insurance coverage dispute over pollution exclusion; insured sought to prove contamination was "sudden and accidental" to trigger exception. Expert testimony excluded as unreliable under Daubert/FRE 702 because expert failed to explain methodology linking plume data to conclusion of sudden release. Without admissible evidence, no genuine issue of material fact; summary judgment for insurer affirmed.

Holdings

1. The district court did not abuse its discretion in excluding Rogers's testimony because it was not based on reliable methods or principles.

Questions Presented

1. Whether the district court abused its discretion in excluding the expert testimony of Daniel Rogers under Daubert.
2. Whether summary judgment was proper given the exclusion of the expert testimony.

Disposition

affirmed