Stringer v. Robin Instrument & Specialty, LLC

Summary

The court denied Ametek’s motion for summary judgment and denied the defendants’ Daubert motion to exclude the testimony of plaintiffs’ expert. The court granted Robin’s motion for summary judgment in part as to plaintiffs’ Louisiana Products Liability Act claims, but denied it as to potential non-manufacturer seller negligence liability. The ruling concerns alleged failure to warn about pressure-unit settings on a digital test gauge involved in a fatal offshore-platform explosion.

Holdings

1. Gleason was qualified to testify as an expert, and the factual bases and methodology underlying his opinions were not so speculative or unreliable as to require exclusion under Rule 702 and Daubert.
2. Ametek was not entitled to summary judgment because plaintiffs presented sufficient evidence to create a genuine dispute of material fact as to whether the Crystal Gauge's alleged failure to warn rendered it unreasonably dangerous.
3. Robin was entitled to summary judgment on plaintiffs' LPLA claims because plaintiffs failed to present evidence that Robin exercised control over or influenced a characteristic of the Crystal Gauge's design, construction, or quality that caused the alleged harm.
4. Robin was not entitled to summary judgment on the non-manufacturer-seller negligence claim because plaintiffs presented sufficient evidence to create a genuine dispute about Robin's actual or constructive knowledge of the alleged defect and its failure to warn.

Questions Presented

1. Whether plaintiffs' expert Glenn H. Gleason was qualified and whether his opinions were sufficiently reliable and non-speculative for admission under Federal Rule of Evidence 702 and Daubert.
2. Whether Ametek was entitled to summary judgment on plaintiffs' Louisiana Products Liability Act failure-to-warn claim.
3. Whether Robin qualified as a manufacturer under the Louisiana Products Liability Act based on alleged modifications or control over the Crystal Gauge.
4. Whether Robin was entitled to summary judgment on plaintiffs' non-manufacturer-seller negligence claim because plaintiffs lacked evidence that Robin had actual or constructive knowledge of the alleged defect or failed to warn.

Disposition

other