Personal injury cases are usually tried in state courts under state law. But when the plaintiff and defendant are citizens of different states–say, an individual plaintiff living in Georgia sues a company based in Florida–then the case may be removed to a federal court. The federal court must still decide the case based on state law. But federal rules govern procedural questions like the admission of evidence. This can sometimes lead to confusion, as the Eleventh Circuit U.S. Court of Appeals in Atlanta recently found.
Cooper v. Marten Transport, Ltd.
In 2010, a husband and wife suffered serious back injuries after a tractor trailer collided with their car in Georgia. The couple sued the other driver and the company that owned the tractor trailer. As the defendants were not Georgia residents, they had the case removed from state to federal court.
The couple offered three expert witnesses to establish their back injuries were the direct result of the accident. The trial judge rejected all three, however, applying what’s known as the Daubert standard. This is a rule announced by the U.S. Supreme Court in a 1993 case dealing with the factors that federal courts should use in deciding whether to admit expert testimony.
In this case, the trial court found one of the couples’ experts “unreliable” under Daubert, and the remaining two witnesses failed to establish a direct link between the accident and the couples’ back pain. Having rejected the three experts, the district court then granted the defendants summary judgment.
The District Court’s Error
The Eleventh Circuit reviews decisions made by federal trial courts in Georgia, Florida and Alabama. The couple appealed the district court’s decision to exclude the experts and grant summary judgment to the defense. On September 27, a three-judge panel of the Eleventh Circuit gave the couple a partial victory: It upheld the exclusion of the experts but reversed the summary judgment, meaning the couple can bring their case to a jury for trial.
When a trial judge court decides to admit or exclude evidence under the Daubert standard, the appeals court will only reverse the judge if there was a clear error (or “abuse of discretion”). The Eleventh Circuit said that wasn’t the case here; the trial judge offered solid reasons for excluding the couples’ three experts.
That said, the district court went a step too far in dismissing the case outright. The Daubert standard is a federal rule. But the couples’ underlying case must be tried under Georgia law. And in Georgia, expert testimony is not necessary to prove causation in a personal injury case. As the Eleventh Circuit said in its written opinion, Georgia allows a jury, acting without specialized medical knowledge, to “infer a causal connection between an accident and a plaintiff’s injuries based on the sequence of events, particularly in the case of automobile collisions.”
The Eleventh Circuit’s decision does not mean the couple will ultimately prevail in their lawsuit. It just means the trial judge was wrong to prevent a jury from making that decision. The case now returns to the federal district court for trial.