Gharda USA, Inc. and Gharda Chemicals, Ltd. v. Control Solutions, Inc., United Phosphorus, Inc., and Mark Boyd, 464 S.W.3d 338

This case arises from a warehouse fire in Pasadena, Texas, involving Gharda Chemicals chlorpyrifos supplied to a blending facility operated by Control Solutions, Inc.
Plaintiffs alleged manufacturing defect, marketing defect, breach of warranties, negligence, and gross negligence; trial produced four expert witnesses on causation and defects.
Plaintiffs’ experts posited that chlorpyrifos contained EDC contamination, which led to an exothermic decomposition or vapor cloud that ignited and spread the fire.
Defense challenged reliability of the experts under the Robinson factors and no-evidence standards; the trial court later granted judgment notwithstanding the verdict in defendants’ favor.
Court of Appeals reversed in a split decision, holding plaintiffs’ expert testimony reliable; Texas Supreme Court granted certiorari to itself review the expert reliability issue.
Texas Supreme Court held all four experts’ testimony unreliable, finding analytical gaps and excessive reliance on speculative assumptions, reversing the appellate ruling and reinstating take-nothing judgment for Gharda.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether plaintiffs’ causation theory required expert testimony	Gharda contends causation lacking without expert support	Gharda asserts experts could rely on independent data to establish causation	Yes; expert proof required and lacking
Whether the four experts’ methodologies were reliable under Robinson factors	Plaintiffs argue Robinson factors met and supported reliability	Gharda argues methodologies unreliable and speculative	Reliability not met; analyses based on mere possibilities
Whether reliance on interdependent expert testimony violated Daubert-like reliability	Experts’ conclusions were collectively sufficient	Interdependent data cannot form a single reliable expert’s support	Interdependent testimony rejected; no single reliable foundation
Whether circumstantial observations by Rice and Russo could support causation without reliable expert testimony	Circumstantial findings, together with experts, prove causation	No evidence of causation without reliable expert analysis	No; circumstantial evidence barred without reliable expert causation proof

Helena Chem. Co. v. Wilkins, 47 S.W.3d 486 (Tex. 2001) (reliability foundation for expert testimony required)
City of Keller v. Wilson, 168 S.W.3d 802 (Tex. 2005) (no-evidence standard and appellate review framework)
Mack Trucks, Inc. v. Tamez, 206 S.W.3d 572 (Tex. 2006) (expert causation must be supported by reliable methodology)
Nissan Motor Co. v. Armstrong, 145 S.W.3d 131 (Tex. 2004) (requires expert testimony to prove product defect causes)
Gen. Motors Corp. v. Iracheta, 161 S.W.3d 462 (Tex. 2005) (probability standard for expert testimony and analytical gaps)
Gammill v. Jack Williams Chevrolet, Inc., 972 S.W.2d 713 (Tex. 1998) (reliability assessment of expert testimony; ipse dixit caution)
Whirlpool Corp. v. Camacho, 298 S.W.3d 631 (Tex. 2009) (no abuse of discretion in exclusions where reliability failed)
City of San Antonio v. Pollock, 284 S.W.3d 809 (Tex. 2009) (reliability and admissibility considerations for expert theory)