## Facts

- Robert K. Joiner worked as an electrician for the City of Thomasville, Georgia, handling electrical transformers whose dielectric fluid sometimes splashed onto him and sometimes contacted his eyes and mouth.
- In 1983, the city discovered some transformer fluid was contaminated with polychlorinated biphenyls (PCBs); Joiner alleged occupational exposure to PCBs and related compounds (furans and dioxins).
- Joiner, a smoker with a family history of lung cancer, was diagnosed in 1991 with small-cell lung cancer.
- Joiner and his wife sued General Electric Company, Monsanto Company, and Westinghouse Electric Corporation on products-liability theories, alleging the exposures promoted his cancer; the case was removed to federal court.
- Defendants sought summary judgment, arguing insufficient exposure and lack of admissible scientific evidence of causation; Joiner relied on expert testimony attributing his cancer to the alleged exposures.
- The district court found a fact issue on exposure but excluded the experts as unreliable under Rule 702 and Daubert, describing the opinions as unsupported by the studies cited, and granted summary judgment for defendants.
- The Eleventh Circuit reversed, applying a “particularly stringent” review to the exclusion of expert testimony.

## Issues

1. What standard of review applies to a district court’s decision to admit or exclude expert scientific testimony under Federal Rule of Evidence 702 and Daubert?
2. Under that standard, did the district court err in excluding Joiner’s causation experts and granting summary judgment?

## Decision

- The Supreme Court held that appellate courts review Rule 702/Daubert admissibility decisions for abuse of discretion.
- The Court rejected a heightened or different appellate standard for exclusions of expert testimony as compared to admissions.
- Applying abuse-of-discretion review, the Court held the district court did not abuse its discretion in excluding Joiner’s expert testimony and granting summary judgment.
- The Court reversed the Eleventh Circuit, reinstating judgment for the defendants.

## Legal Principles

- A district court’s decision to admit or exclude expert testimony under Rule 702 is reviewed on appeal for abuse of discretion.
- Appellate courts may not apply a categorically more searching review to exclusions than to admissions of expert evidence.
- In assessing reliability, courts may consider whether there is “too great an analytical gap” between the data cited (including animal and epidemiological studies) and the expert’s causation conclusion.
- Methodology and conclusions are not wholly separable; when an opinion rests primarily on the expert’s say-so rather than adequate support, exclusion may be within the trial court’s discretion.

## Conclusion

The Court confirmed that trial judges have broad discretion as Daubert gatekeepers and that appellate courts must defer absent abuse of discretion, including where the trial court finds the studies and data too attenuated to support the expert’s causation opinion.


Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1997)