## Facts

- Twelve-year-old Natalie Calhoun rented and operated a Yamaha Wavejammer personal watercraft in Puerto Rico despite a warning label stating a minimum operator age of fourteen.
- Natalie, with no prior experience, drove the craft at high speed toward an anchored boat, did not steer away, and collided, resulting in her death.
- The craft used a squeeze-finger throttle; plaintiffs alleged this design could cause a frightened operator to clench and inadvertently maintain or increase throttle.
- Natalie’s parents sued Yamaha under maritime jurisdiction, asserting strict products liability (design defect and warning defect), negligence, and breach of implied warranties based on the throttle design and warnings.
- Plaintiffs offered three experts: a psychologist (stress/clenching theory without testing), a marine-safety expert (experience-based opinions without engineering basis or comparative testing), and a marine engineer (criticisms without personal operation at the time of report or comparative testing).
- The district court excluded or limited major portions of the experts’ testimony under Federal Rule of Evidence 702, granted judgment as a matter of law for Yamaha on negligence, and submitted strict-liability defect and warning claims to the jury.
- The jury found for Yamaha on the strict-liability claims; plaintiffs appealed evidentiary rulings, the negligence directed verdict, and instructions allowing consideration of nonparty negligence; Yamaha cross-appealed seeking broader exclusion of expert testimony.

## Issues

1. Whether the district court abused its discretion under Federal Rule of Evidence 702 by excluding or limiting plaintiffs’ expert testimony for lack of reliability and fit.
2. Whether the district court properly granted judgment as a matter of law for Yamaha on plaintiffs’ negligence claims.
3. Whether jury instructions permitting consideration of negligence of nonparties were erroneous and, if so, whether any error was harmless.
4. Whether the district court erred by admitting any portion of plaintiffs’ expert testimony (Yamaha’s cross-appeal).

## Decision

- The Third Circuit affirmed the judgment for Yamaha.
- The district court did not abuse its discretion in limiting or excluding expert opinions that lacked sufficient facts or data, reliable methods, or a reliable application to the accident.
- The directed verdict for Yamaha on negligence was affirmed because the evidence, as constrained by proper Rule 702 rulings, was insufficient for a reasonable jury to find negligent design, testing, or warnings.
- Any potential error in instructions concerning nonparty negligence was harmless because the jury first found the product not defective.
- Yamaha’s cross-appeal was rejected; the limited admission of some expert testimony fell within the trial court’s discretion.

## Legal Principles

- Rule 702 requires expert testimony to satisfy three distinct requirements: qualification, reliability, and fit (relevance and helpfulness to the factfinder).
- Reliability demands “good grounds”: opinions must rest on methods and procedures of science rather than subjective belief or unsupported speculation, typically supported by testing, validation, or other dependable indicia.
- Fit requires that the expert’s reasoning and methodology connect to the case-specific questions in a way that assists the jury, not merely offering general criticisms untethered to the facts.
- Trial courts have a gatekeeping role under Rule 702, and appellate review of admissibility decisions is for abuse of discretion.
- In maritime cases applying comparative fault principles, an instructional error regarding nonparty fault does not warrant reversal absent prejudice; where the jury finds no defect, allocation-of-fault issues cannot affect the outcome.

## Conclusion

The Third Circuit upheld a defense verdict in a maritime products-liability action, holding that the district court acted within its discretion under Rule 702 in restricting unsupported expert opinions, properly removed negligence claims from the jury for insufficient evidence, and that any contested nonparty-fault instruction could not have changed the result given the jury’s no-defect finding.


Calhoun v. Yamaha Motor Corp., U.S.A., 350 F.3d 316 (3d Cir. 2003)