Reyes v. Apple, Inc.

Summary

The United States District Court for the Northern District of California grants Apple’s motion to exclude plaintiffs’ causation expert, Dr. Yoav Hahn, and grants Apple’s motion for summary judgment in an AirPods-related personal injury and product liability action. The court concludes that plaintiffs failed to establish reliable general or specific causation for the alleged hearing injury from a brief 113.5-decibel Amber Alert delivered through AirPods Pro.

Holdings

1. Dr. Hahn was not qualified to offer a general-causation opinion regarding the sound level capable of causing the alleged hearing injury, and his opinion was not supported by reliable scientific methodology or objective evidence. His testimony was excluded under Federal Rule of Evidence 702 and Daubert.
2. Plaintiffs failed to present admissible evidence from which a reasonable trier of fact could find that a brief exposure to sound of no more than 113.5 decibels through an AirPods Pro earbud was capable of causing the alleged hearing injury. Because general causation was unsupported, Apple was entitled to summary judgment.
3. Plaintiffs failed to present admissible evidence from which a reasonable trier of fact could find that the Amber Alert played through B.G.'s AirPods Pro actually caused his injuries. Dr. Hahn's specific-causation opinion was unreliable because it depended on an unsupported differential diagnosis and failed to reliably rule out COVID-related viral labyrinthitis or other plausible causes.
4. Apple was entitled to summary judgment on all of plaintiffs' remaining claims because causation was an essential element of each claim and plaintiffs had no admissible evidence establishing either general or specific causation.

Questions Presented

1. Whether Dr. Yoav Hahn's causation opinions were admissible under Federal Rule of Evidence 702 and Daubert.
2. Whether plaintiffs presented sufficient admissible evidence of general causation to show that a brief exposure to sound of no more than 113.5 decibels through AirPods Pro could cause the alleged hearing injury.
3. Whether plaintiffs presented sufficient admissible evidence of specific causation to show that the Amber Alert played through B.G.'s AirPods Pro actually caused his injuries.
4. Whether Apple was entitled to summary judgment on plaintiffs' negligence, strict-liability, breach-of-implied-warranty, and negligent-infliction-of-emotional-distress claims because plaintiffs lacked evidence of causation.
5. Whether plaintiffs' motion for partial summary judgment on Apple's comparative-negligence defense remained justiciable after summary judgment was granted for Apple on all claims.

Disposition

other