Good v. BioLife Plasma Services, L.P., 1:18-cv-11260

Plaintiff Tenley McLaughlin Good fainted seconds after a capillary finger‑prick at a BioLife plasma donation center, fell from her swiveling chair, and suffered concussion‑related injuries she now attributes to hearing loss and personality changes.
Good sued BioLife and Shire alleging (1) negligent intake (failure to ask about prior fainting at sight of blood) and (2) negligent positioning (use of a high swiveling chair and improper phlebotomist placement).
The district court initially granted summary judgment for Defendants, finding Plaintiff’s affidavit conflicted with deposition testimony and that fainting was too unlikely to impose a duty; the Sixth Circuit reversed in part, finding foreseeability and factual disputes for a jury.
Defendants moved to exclude Plaintiff’s two experts (Sean T. Stanley and Nancy Erickson) under Daubert, arguing they lack plasma‑donation experience and reliable bases for their opinions; they also sought leave to file a second summary‑judgment motion on causation if experts were excluded.
After a Daubert hearing, the court found both experts highly qualified in phlebotomy, concluded their experience‑based opinions were sufficiently reliable and relevant despite lacking plasma‑center experience, and denied exclusion.
The court also denied leave to file a second summary‑judgment motion, concluding causation/proximate‑cause issues remain fact questions and that exclusion of the experts was unlikely to produce a different outcome.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of experts under Fed. R. Evid. 702/Daubert	Stanley and Erickson are qualified phlebotomy experts whose experience reliably applies to capillary blood collection and breach/causation opinions	Experts lack plasma‑donation experience, failed to apply methodology/empirical testing, and so their testimony is unreliable	Denied: experts admissible; experience‑based opinions are reliable and relevant; shortcomings go to weight, not admissibility
Leave to file second motion for summary judgment on causation and proximate cause	N/A (Defendants sought leave to renew SJ if experts excluded)	Excluding experts would permit Defendants to seek summary judgment that Plaintiff lacks admissible causation evidence and injuries are not natural/probable result	Denied: experts not excluded; even if excluded, lay testimony (e.g., eyewitness of swivel) and factual disputes make causation/proximate cause jury questions rather than appropriate for summary judgment

Daubert v. Merrell Dow Pharm., 509 U.S. 579 (1993) (trial court gatekeeping for expert admissibility under Rule 702)
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) (Daubert gatekeeping applies to all expert testimony; reliability inquiry is context‑specific)
Thomas v. City of Chattanooga, 398 F.3d 426 (6th Cir. 2005) (experience‑based expert testimony may be admissible if expert explains how experience leads to conclusions)
Surles ex rel. Johnson v. Greyhound Lines, Inc., 474 F.3d 288 (6th Cir. 2007) (reiterating context‑specific reliability inquiry tied to case facts)
Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1997) (expert testimony may be excluded where opinion lacks adequate factual or methodological support)
Good v. BioLife Plasma Servs., L.P., [citation="834 F. App'x 188"] (6th Cir. 2020) (reversing summary judgment, holding fainting risk during capillary draw was foreseeable and factual disputes exist on causation)
Case v. Consumers Power Co., 615 N.W.2d 17 (Mich. 2000) (setting elements of negligence)