## Facts

- Douglas Norman Rudd was injured when a fan blade from his 1970 General Motors pickup truck broke loose and struck his head, neck, and left arm while the hood was open and he was working at the front of the vehicle.
- Rudd sued General Motors Corporation in federal court under diversity jurisdiction, seeking substantial damages for serious, permanent injuries.
- Rudd alleged the fan was defective when it left the manufacturer’s control and that the defect proximately caused the blade separation and resulting injuries.
- He asserted three product-defect theories under the Alabama Extended Manufacturer’s Liability Doctrine (AEMLD): (1) manufacturing defect (metal flaw leading to fatigue failure), (2) design defect (no protective fan guard), and (3) warning defect (inadequate warnings regarding blade separation).
- He also alleged negligence based on the asserted failure to provide a guard and adequate warnings.
- Rudd’s proof relied heavily on a mechanical-engineering expert who could not identify a specific defect in the subject fan, but opined that the fan “must have been defective” after ruling out other potential causes and relying on engineering experience and generalized failure analyses.

## Issues

1. Whether the plaintiff’s engineering expert offered admissible testimony under Federal Rule of Evidence 702 and Daubert to support an inference of defect and causation.
2. Whether, absent direct proof of a specific defect, the plaintiff produced sufficient evidence under Alabama law (AEMLD and negligence) to create a genuine dispute of material fact on manufacturing defect, design defect (no guard), and warning defect.
3. Whether summary judgment was required on any claim for which the plaintiff’s only proof of defect or causation depended on excluded or unreliable expert testimony.

## Decision

- The court exercised its gatekeeping function under Rule 702 and Daubert to evaluate the reliability and fit of the expert’s defect opinions.
- The court concluded that portions of the expert’s opinions were inadequately supported because they inferred defect primarily from the fact of failure and an asserted elimination of alternative causes, without sufficiently rigorous, case-specific analysis of the failed component.
- The court granted General Motors’s summary-judgment motion in part and denied it in part, narrowing the case by disposing of claims that depended on inadmissible or insufficient expert proof.
- To the extent any claim survived, it did so only on the basis of minimally sufficient, admissible evidence; theories resting on speculative inference were removed from the case at the summary-judgment stage.

## Legal Principles

- Under Federal Rule of Evidence 702 and Daubert, technical expert testimony must be based on reliable methods reliably applied to the facts, and must assist the trier of fact through more than speculation.
- In products-liability cases, when expert testimony is the only evidence on defect or causation, exclusion or limitation of that testimony may require summary judgment on the affected claims.
- An expert’s “elimination of alternatives” approach can be insufficient where it is not supported by objective, testable, case-specific examination (for example, testing, measurements, or recognized failure analysis of the actual component).
- Under Alabama’s AEMLD, a plaintiff must present evidence that the product was defective and unreasonably dangerous when it left the manufacturer’s control and that the defect proximately caused the injury; conjectural defect inferences do not satisfy this burden.

## Conclusion

The court applied Daubert and Rule 702 to restrict defect opinions that were not grounded in reliable, case-specific engineering methodology, and it granted summary judgment on product-defect and related negligence theories that lacked competent proof once the expert testimony was limited, allowing only any narrowly supported claims to proceed.


Rudd v. Gen. Motors Corp., 127 F. Supp. 2d 1330 (M.D. Ala. 2001)