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State Farm Fire & Casualty Co. v. IDC Management Co.

United States District Court, M.D. Pennsylvania

October 25, 2019

STATE FARM & CASUALTY COMPANY a/s/o THOMAS UHLEIN, Plaintiff,
v.
IDC MANAGEMENT COMPANY d/b/a M&M Services, Defendant.

          MEMORANDUM OPINION

          KAROLINE MEHALCHICK UNITED STATES MAGISTRATE JUDGE

         This is an action concerning property damage arising out of a fire in June 2017 that occurred in a vacant vacation home in Tannersville, Pennsylvania, after it had been cleaned. Pending before the Court are two motions filed by Defendant, IDC Management Company d/b/a M&M Services. First, Defendant has filed a motion to preclude the Plaintiff from offering expert opinion in advance of trial in this matter, and the Court now addresses this motion brought pursuant to Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 595 (1993) and Federal Rule of Evidence 702, to exclude all of the expert testimony and written reports of Robert Buckley. (Doc. 33). Defendant has also filed a motion for summary judgment, submitting that it is entitled to summary judgment due to the speculative nature of Buckley's testimony. (Doc. 31). For the following reasons, the Court will deny both motions.

         I. Federal Rule 702 and Expert Testimony

         Federal courts are vested with broad inherent authority to manage their cases, which carries with it the discretion and authority to rule on motions in limine prior to trial. See Luce v. United States, 469 U.S. 38, 41 n.4 (1984); In re Japanese Elec. Prods. Antitrust Litig., 723 F.2d 238, 260 (3d Cir. 1983) (noting that the court exercises its discretion to rule in limine on evidentiary issues “in appropriate cases”), rev'd on other grounds sub nom., Matsushita Elec. Indus. Co. v. Zenith Radio Corp., 475 U.S. 574 (1986). Courts may exercise this discretion in order to ensure that juries are not exposed to unfairly prejudicial, confusing, or irrelevant evidence. United States v. Romano, 849 F.2d 812, 815 (3d Cir. 1988). Courts may also do so in order to “narrow the evidentiary issues for trial and to eliminate unnecessary trial interruptions.” Bradley v. Pittsburgh Bd. of Educ., 913 F.2d 1064, 1069 (3d Cir. 1990) (citation omitted).

         Federal Rule of Evidence 702 governs the admissibility of expert testimony and requires an expert witness to have “specialized knowledge” regarding the area of testimony. Rule 702 provides:

A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if:
(a) the expert's scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue;
(b) the testimony is based on sufficient facts or data;
(c) the testimony is the product of reliable principles and methods; and
(d) the expert has reliably applied the principles and methods to the facts of the case.

Fed. R. Evid. 702.

         “Rule 702 has three major requirements: (1) the proffered witness must be an expert, i.e., must be qualified; (2) the expert must testify about matters requiring scientific, technical or specialized knowledge[, i.e. reliability]; and (3) the expert's testimony must assist the trier of fact[, i.e., fit].” United States v. Schiff, 602 F.3d 152, 172 (3d Cir. 2010) (alterations in original) (quoting Pineda v. Ford Motor Co., 520 F.3d 237, 244 (3d Cir. 2008)).

         In general, the Federal Rules of Evidence embody a strong preference for admitting any evidence that may assist the trier of fact. Fed.R.Evid. 402. Moreover, Rule 702 in particular “has a liberal policy of admissibility.” Kannankeril v. Terminix Int'l, Inc., 128 F.3d 802, 806 (3d Cir. 1997).

         First, an expert is qualified if “the witness possess[es] specialized expertise.” Schneider ex rel. Estate of Schneider v. Fried, 320 F.3d 396, 404 (3d Cir. 2003). The United States Court of Appeals for the Third Circuit interprets the qualification requirement liberally, and notes that “a broad range of knowledge, skills, and training qualify an expert as such.” In re Paoli R.R. Yard PCB Litig.,35 F.3d 717, 741 (3d Cir. 1994); Betterbox Commc'ns Ltd. v. BB Techs., Inc., 300 F.3d 325, ...


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