Eleventh Circuit Upholds Judgment For Car Manufacturer In Case Involving Fuel Shut-Off Switch

The Eleventh Circuit affirmed a district court’s exclusion of expert witness testimony and a grant of summary judgment for a defendant car manufacturer in a wrongful death action brought by the plaintiff’s estate.  The estate alleged that the car manufacturer’s failure to equip the vehicle with a fuel shut-off switch led to the plaintiff’s fatal brain injury after her car collided with a Mack truck and “pinballed” into two parked cars and other obstacles.

The appellate court concluded that the district court did not abuse its discretion in excluding the plaintiff’s expert testimony given that the expert never fully explained how his experience, methodology, and the literature upon which he based his ultimate opinion actually supported that opinion.  The court explained that such vague description, coupled with the expert’s inability to rule out other causes of the traumatic brain injury, supported the district court’s decision to exclude the evidence, noting that the “leap from data to opinion” in this case” was “too great.”  Without the existence of expert testimony, there was no evidence supporting the plaintiff’s theory that the lack of a fuel shut-off switch was the actual cause of the injury.  Accordingly, the Eleventh Circuit affirmed the district court’s grant of summary judgment and dismissal of the case.