## Facts

- A vehicle occupant was injured in a motor-vehicle crash involving a Chrysler-manufactured vehicle.
- The plaintiff sued the vehicle manufacturer under product-liability theories, alleging a defect and that the defect caused or worsened the injuries.
- The plaintiff relied on expert testimony to establish defect and causation.
- The district court excluded key expert opinions and entered summary judgment for the manufacturer due to insufficient proof.
- The plaintiff appealed.

## Issues

1. Whether the district court abused its discretion by excluding the plaintiff’s expert testimony under Federal Rule of Evidence 702 and the Daubert standard.
2. Whether, without the excluded expert testimony, the plaintiff produced sufficient evidence to create a triable issue on defect and causation.
3. Whether summary judgment for the manufacturer was proper.

## Decision

- The Seventh Circuit affirmed.
- The court held the district court acted within its discretion in excluding the expert testimony offered to prove defect and causation.
- With the expert opinions excluded, the plaintiff lacked evidence sufficient to support essential elements of the product-liability claims.
- Summary judgment for the manufacturer was therefore proper.

## Legal Principles

- Under Rule 702 and Daubert, expert opinions must be based on reliable methods and a reliable application of those methods to the facts of the case.
- Appellate review of a trial court’s Daubert ruling is deferential; reversal requires a clear abuse of discretion.
- In product-liability cases alleging a defect that caused or enhanced injury, plaintiffs ordinarily must present admissible expert evidence to prove defect and causation when those matters are beyond common experience.
- When a party lacks admissible evidence on an essential element, summary judgment is required.

## Conclusion

The court affirmed judgment for the manufacturer because the plaintiff’s defect-and-causation case depended on expert testimony that was properly excluded as unreliable, leaving no triable evidence on essential elements.


May v. Chrysler Grp., L.L.C., 716 F.3d 963 (7th Cir. 2013)