Perez-Garcia v. Puerto Rico Ports Authority
3:08-cv-01448
D.P.R.Jul 6, 2012Background
- Plaintiff Perez-Garcia sued PRPA, CAF, and insurers for damages when a golf cart fell from a second-floor VRC at SJU Airport.
- CAF filed a third-party complaint against KF, Antilles, Club Car, and Bayamon Golf for contribution/indemnity if CAF is liable.
- Dispute centers on two in limine motions to exclude expert Renfroe’s testimony (Plaintiffs' motion and Club Car's motion).
- Renfroe’s opinions relate to safety standards, vehicle maintenance, braking system design, and accident reconstruction.
- Court granted in part and denied in part both motions, applying Rule 702 and Daubert standards for expert testimony.
- Order issued July 6, 2012, by Judge Gustavo A. Gelpi.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Renfroe’s Opinion No. 2 and Final Opinion are admissible | Opinions rely on open/open-possibility facts, not scientific methodology. | Opinions rely on Renfroe’s expertise and are relevant to causation and design. | Excluded Opinion No. 2 and Final Opinion; limitations on opinion. |
| Whether Renfroe’s Opinions Nos. 3 and 3(d) are admissible | No factual basis to support those specific possibilities. | As accident-reconstruction analyst, Renfroe may explore multiple possibilities. | Denied; opinions related to data and within expert’s methodology are admissible. |
| Whether Club Car’s objection to Renfroe’s reliance on prior incidences is admissible | Prior incidents are relevant to defect patterns and causation. | Prior incidents must be dissimilar or properly admissible under rules. | Renfroe may testify on relevant defects but prior similar incidences dissimilar to the present are excluded. |
Key Cases Cited
- Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (Sup. Ct. 1993) (gatekeeping reliability standard for expert testimony)
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (Sup. Ct. 1999) (flexible Daubert standard for all expert testimony)
- Mooney v. United States, 315 F.3d 54 (1st Cir. 2002) (four Daubert factors guide reliability of testimony)
- Joiner v. Gen. Elec. Co., 522 U.S. 136 (Sup. Ct. 1997) (analytical gap between data and opinion acceptable within limits)
- Ruiz-Troche v. Pepsi Cola of P.R. Bottling Co., 161 F.3d 77 (1st Cir. 1998) (data-reliance and methodological fit in expert analysis)