Earl Parris, Jr. v. 3M Company, et al.

Summary

The United States District Court for the Northern District of Georgia denied defendants’ motion to exclude the expert testimony of Andrew Stahl in a Clean Water Act action concerning PFAS contamination of surface and drinking water in Chattooga County, Georgia. The court held that challenges to Stahl’s upstream, downstream, and groundwater sampling data primarily concerned the weight of his opinions and were appropriate for cross-examination rather than exclusion under Federal Rule of Evidence 702. The opinion and order was signed by Judge Thomas W. Thrash, Jr., on March 20, 2026.

Holdings

1. Stahl's opinions were sufficiently supported under Federal Rule of Evidence 702 despite PFAS detections in samples taken upstream of the sludge-application fields. Defendants' challenges to his interpretation of the samples were principally matters for cross-examination and competing evidence, not exclusion.
2. The downstream sampling inconsistencies identified by defendants did not require exclusion of Stahl's testimony.
3. Stahl's groundwater sampling methodology was reliable under Rule 702 despite high turbidity readings and defendants' reliance on EPA guidance recommending lower turbidity.

Questions Presented

1. Whether Stahl's expert testimony was sufficiently reliable under Federal Rule of Evidence 702 and Daubert despite defendants' challenges to upstream sampling data.
2. Whether Stahl's expert testimony was sufficiently reliable despite allegedly inconsistent downstream PFAS concentrations.
3. Whether Stahl's groundwater sampling methodology was sufficiently reliable despite high turbidity readings and alleged noncompliance with EPA groundwater-sampling guidance.

Disposition

other