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Brown v. Crown Equipment Corp.10/27/2005
Charles Brown ("Mr. Brown") and Barbara Sue Reynolds ("Mrs. Reynolds") sustained injuries to their left legs while operating two different models of stand-up forklifts manufactured by Crown Equipment Corporation ("Crown"). Mr. Brown and Mrs. Reynolds brought product liability claims against Crown alleging that their injuries were caused by the defective nature of the forklifts. Mrs. Reynolds' husband, Howard Reynolds ("Mr. Reynolds"), sought compensation from Crown based upon loss of consortium.
Prior to trial, Mr. Brown, Mrs. Reynolds, and Mr. Reynolds (collectively "the plaintiffs") as well as Crown filed motions in limine seeking to preclude the opposing parties' experts from testifying at trial. The trial court denied the motions and permitted the experts of both parties to testify at trial. During trial, the plaintiffs presented the testimony of Richard Johannson ("Mr. Johannson"), a mechanical engineer, and Dr. Gerald Harris ("Dr. Harris"), a biomechanical engineer. Both Mr. Johannson and Dr. Harris opined that the injuries of Mr. Brown and Mrs. Reynolds would not have occurred had Crown installed rear doors on the operator compartments of the forklifts.
At the close of Crown's proof, Crown renewed its motion to exclude the testimony of Mr. Johannson and Dr. Harris and moved for a directed verdict on all issues of liability. The trial court excluded the expert testimony of Mr. Johannson and Dr. Harris as unreliable under McDaniel v. CSX Transportation, Inc., 955 S.W.2d 257 (Tenn. 1997). The trial court also granted Crown's motion for a directed verdict, finding that without the expert testimony the plaintiffs failed to establish that Crown was negligent or that its forklifts "were defective or unreasonably dangerous or that the forklifts were not merchantable or fit for the particular purpose for which they were manufactured."
The Court of Appeals affirmed the judgment of the trial court. We granted review.
ANALYSIS
A. Overview of the Admissibility of Expert Testimony
Generally, questions pertaining to the qualifications, admissibility, relevancy, and competency of expert testimony are matters left to the trial court's discretion. McDaniel, 955 S.W.2d at 263. We may not overturn the trial court's ruling admitting or excluding expert testimony unless the trial court abused its discretion. Id. at 263-64. A trial court abuses its discretion if it applies an incorrect legal standard or reaches an illogical or unreasonable decision that causes an injustice to the complaining party. State v. Stevens, 78 S.W.3d 817, 832 (Tenn. 2002).
Tennessee Rules of Evidence 702 and 703 govern the admissibility of expert testimony in Tennessee. Rule 702 states that " f scientific, technical, or other specialized knowledge will substantially assist the trier of fact to understand the evidence or to determine a fact in issue, a witness qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise." Rule 703 provides:
The facts or data in the particular case upon which an expert bases an opinion or inference may be those perceived by or made known to the expert at or before the hearing. If of a type reasonably relied upon by experts in the particular field in forming opinions or inferences upon the subject, the facts or data need not be admissible in evidence. The court shall disallow testimony in the form of an opinion or inference if the underlying facts or data indicate lack of trustworthiness.
The trial court, therefore, must determine that the expert testimony is reliable in that the evidence will substantially assist the trier of f
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