Lejeune v. American Inter-Fidelity Exchange, 2:23-cv-01364

Plaintiff Jean Joyce Lejeune alleges injury from a collision with an 18-wheeler while driving on I-10, involving a disputed lane deviation.
Defendant American Inter-Fidelity Exchange, insurer of the trucking company, retained Richard V. Baratta as a biomechanical engineering expert.
Plaintiff filed a motion in limine to exclude Baratta's testimony and expert report, challenging his qualifications and methodology.
The court, sitting as gatekeeper under Daubert, evaluated the admissibility of Baratta's opinions for relevance, reliability, and qualification.
Plaintiff is claiming over $1.8 million in future medical expenses, and causation of injuries is in dispute.
The court considered both sides' arguments and the materials relied on by Baratta in forming his opinions.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Admissibility of Baratta's Expert Testimony	Baratta's opinions are methodologically flawed and he is unqualified; testimony is based on insufficient and unreliable data.	Baratta's methods are accepted, he relied on sufficient industry-standard data, and his qualifications are appropriate.	Motion to exclude denied; challenges go to weight, not admissibility.
Use of Photographs and Reports in Expert Analysis	Baratta not qualified to interpret photographs, did not rely on certain witness statements or specific repair estimates.	Experts commonly use such materials, and reliance on different data is customary.	Court finds no merit in plaintiff's objections; standard expert practices upheld.
Absence of Certain Methodologies (e.g., scene inspection, calculations)	Baratta did not use peer-reviewed or quantifiable methods (e.g., no G-force, delta-v, or speed calculations).	Baratta used accepted crash analysis software, reports, and available physical evidence.	Court finds Daubert criteria met; method adequacy is for the jury to weigh.
Qualifications of Expert	Baratta lacks the specific qualifications to render biomechanical/biomedical opinions.	Baratta is qualified based on credentials and experience; no substantive challenge to his credentials.	Court finds Baratta qualified; no exclusion warranted.

Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (establishes trial court's role as gatekeeper for expert testimony, emphasizing reliability and relevance)
Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (extends Daubert's gatekeeping to all expert testimony, not just scientific)
Mathis v. Exxon Corp., 302 F.3d 448 (sets burden on proponent to establish admissibility of expert testimony by preponderance)
Guy v. Crown Equipment Corp., 394 F.3d 320 (affirms trial court’s broad latitude in admitting expert evidence)
Moore v. Ashland Chemical, Inc., 151 F.3d 269 (notes factors for assessing expert methodology under Daubert)