Kumho Tire Co., Ltd. v. Carmichael
| Kumho Tire Co. v. Carmichael | |
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| Argued December 7, 1998 Decided March 23, 1999 |
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| Full case name | Kumho Tire Company, Ltd., et al. v. Patrick Carmichael et al. |
| Citations | 526 U.S. 137 (more)
119 S. Ct. 1167; 143 L. Ed. 2d 238; 1999 U.S. LEXIS 2189; 67 U.S.L.W. 4179; 50 U.S.P.Q.2D (BNA) 1177; 50 Fed. R. Evid. Serv. (Callaghan) 1373; CCH Prod. Liab. Rep. P15,470; 99 Cal. Daily Op. Service 2059; 29 ELR 20638; 1999 Colo. J. C.A.R. 1518; 12 Fla. L. Weekly Fed. S 141
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| Prior history | On writ of certiorari to the United States Court of Appeals for the Eleventh Circuit |
| Holding | |
| In a trial in a U.S. federal court, the Daubert Standard governs the admission of expert testimony from non-scientists as well. | |
| Court membership | |
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| Case opinions | |
| Majority | Breyer, joined by Rehnquist, O'Connor, Scalia, Kennedy, Souter, Thomas, Ginsburg |
| Concurrence | Scalia, joined by O'Connor, Thomas |
| Concur/dissent | Stevens |
| Laws applied | |
| Daubert Standard, Federal Rule of Evidence 702 | |
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999), is a United States Supreme Court case that applied the Daubert standard to expert testimony from non-scientists.
Patrick Carmichael was driving his minivan on July 6, 1993, when the right rear tire blew out. One of the passengers in the vehicle died, and others were severely injured. Three months later, the Carmichaels sued the manufacturer of the tire, claiming that the tire was defective and the defect caused the accident. The Carmichaels' case rested largely on testimony from a tire failure expert.
The tire failure expert relied on features of tire technology that the manufacturer did not dispute, as well as background facts about the particular tire on the Carmichaels' van. The expert's conclusion that a defect in the tire caused the accident rested on certain observations about the tire that Kumho Tire vigorously disputed. Kumho also disagreed with certain aspects of the tire expert's methodology, and asked the federal district court hearing the case to exclude it under Rule 702 of the Federal Rules of Evidence.
The district court took its cue from Daubert v. Merrell Dow Pharmaceuticals, which had solidified a gatekeeping role for trial judges in admitting expert testimony. Under Daubert, certain factors contribute to the reliability, and hence the admissibility, of expert testimony, one of which is the general validity of the expert's methods. The district court found the tire expert's methods not to be scientifically valid, and hence excluded his testimony. This resulted in a conclusion that Kumho Tire would rightly prevail. The Carmichaels appealed to the Eleventh Circuit.
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