## Facts

- A tire on a vehicle driven by Patrick Carmichael blew out, the vehicle overturned, one passenger died, and others were injured.
- The survivors and decedent’s representative sued the tire’s manufacturer and distributor in federal court under diversity jurisdiction, alleging a defect caused the blowout.
- Plaintiffs relied on expert testimony from a tire failure analyst, Dennis Carlson, Jr., who planned to opine that a manufacturing or design defect caused the failure.
- Carlson based his opinion on a visual and tactile inspection and a method inferring defect when fewer than two of four physical signs of abuse were present.
- Kumho challenged the methodology and reliability of Carlson’s proposed expert opinion under Federal Rule of Evidence 702.

## Issues

1. Whether the trial judge’s Daubert reliability gatekeeping duty under Federal Rule of Evidence 702 applies only to “scientific” testimony or to all expert testimony based on “scientific, technical, or other specialized knowledge.”
2. Whether the district court abused its discretion by applying a Daubert-type reliability analysis to Carlson’s technical/experience-based testimony and excluding it.

## Decision

- The Supreme Court reversed the Eleventh Circuit and upheld the district court’s exclusion of Carlson’s testimony and the resulting summary judgment for Kumho.
- The Court held that Daubert’s gatekeeping obligation applies to all expert testimony under Rule 702, not only to testimony labeled “scientific.”
- The Court held that Daubert’s listed factors may be used when helpful, but the reliability inquiry is flexible and case-specific.
- Applying deferential abuse-of-discretion review, the Court concluded the district court acted within its discretion in finding Carlson’s methodology insufficiently reliable.

## Legal Principles

- Federal Rule of Evidence 702 requires trial judges to screen expert testimony for relevance and reliability, whether the expertise is scientific, technical, or otherwise specialized.
- Courts may consider Daubert factors (e.g., testing, peer review, error rate, general acceptance) as tools; no fixed checklist is required in every case.
- The reliability analysis must fit the nature of the expertise and the particular facts, focusing on whether the expert’s reasoning and methodology are reliably applied.
- Appellate review of expert-admissibility rulings is for abuse of discretion, giving trial courts broad latitude in performing the gatekeeping function.

## Conclusion

The Court held that Rule 702 imposes a single reliability gatekeeping requirement for all expert testimony, and it reaffirmed that trial courts have flexible, case-specific discretion to evaluate reliability, with appellate courts reviewing those determinations deferentially for abuse of discretion.


Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999)