Brown v. Crown Equipment Corp.

Summary

The Supreme Court of Tennessee held that the trial court improperly rigidly applied all five McDaniel reliability factors when excluding the plaintiffs’ expert testimony in a products liability action involving stand-up forklifts. The court concluded that the experts’ experience-based methodologies could be reliable even without independently conducted testing or peer review, and that the trial court therefore erred in excluding their testimony. The court also held that the directed verdict for Crown Equipment Corporation was erroneous and remanded for further proceedings.

Holdings

1. The McDaniel factors are nonexclusive and are not mandated in every case involving expert evidence. A trial court need apply only those factors that reasonably measure the reliability of the particular expert's methodology.
2. The trial court erred in excluding the testimony of both plaintiffs' experts because it applied all five McDaniel factors rigidly and used factors that did not adequately measure the reliability of their experience-based methodologies.
3. The directed verdict for Crown was improper because, viewing the evidence in the light most favorable to the plaintiffs, reasonable minds could disagree about whether the forklifts were defective or unreasonably dangerous.

Questions Presented

1. Whether the trial court improperly treated all five McDaniel reliability factors as mandatory in evaluating the plaintiffs' expert testimony.
2. Whether the trial court properly excluded the testimony of the plaintiffs' mechanical and biomechanical engineering experts as unreliable.
3. Whether the trial court properly directed a verdict for Crown on the plaintiffs' claims that the forklifts were defective or unreasonably dangerous.

Disposition

reversed_and_remanded