Richard Clark v. River Metals Recycling, LLC, 929 F.3d 434

Background

Plaintiff Richard Clark, a maintenance worker, injured his elbow after slipping from a mobile RB6000 Logger/Baler (the "Crusher") used by his employer, alleging hydraulic fluid on a front platform about five feet above ground.
Clark sued the manufacturer Sierra International Machinery, LLC and lessor River Metals Recycling, LLC in Illinois state court for defective design (insufficient platform/handrails/ladder); defendants removed to federal court on diversity grounds.
Clark proffered mechanical-engineering expert Dr. James Blundell, who opined the Crusher should have had a ladder, toeboards, and guardrails and cited an ANSI standard; his report was brief and offered no developed alternative design drawings or cost/feasibility analysis.
The district court excluded Dr. Blundell’s testimony under Federal Rule of Evidence 702 (Daubert framework) as conclusory, methodologically thin, and inaccurate in its characterization of the ANSI standard; it also rejected reliance on a defendant employee’s testimony as an adequate substitute.
With no admissible expert on design defect, the district court granted summary judgment for both defendants; it also denied leave to amend to add a failure-to-warn claim (Clark did not appeal that denial).
On appeal the Seventh Circuit affirmed, holding expert testimony was required under Illinois’s risk-utility framework and the district court did not abuse its discretion in excluding Dr. Blundell or in deciding no hearing was necessary.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether district court abused discretion by excluding plaintiff's expert under Rule 702	Blundell’s qualifications and concise report were sufficient; no hearing required and missing manufacturer drawings excused lack of detail	Expert was conclusory, misread ANSI, lacked machine-specific knowledge and alternative-design analysis	Exclusion affirmed — court reasonably found methodology unreliable and conclusions unsupported
Whether a hearing was required before excluding the expert	Court should have held a Daubert hearing to probe Blundell’s methodology	Hearing not required; district court can resolve admissibility on submitted materials	No error — district court did not abuse discretion by ruling without a hearing
Whether expert testimony was necessary or common sense sufficed under Illinois product-liability law	Design defect (lack of ladder/rail) was obvious to lay jurors; expert not required	Design-defect inquiry implicates risk-utility factors (feasibility, cost, alternatives) that require specialized proof	Expert testimony required under Illinois risk-utility/ integrated test; summary judgment affirmed for lack of admissible expert evidence
River Metals’ alternative defenses (e.g., non-manufacturer under 735 ILCS 5/2-621)	N/A on appeal (River Metals sought affirmance on any ground)	River Metals argued procedural statutory defenses and lessor non-liability	Court declined to decide statutory/timing defenses because judgment affirmed on merits; noted cross-appeal not necessary

Key Cases Cited

Daubert v. Merrell Dow Pharms., 509 U.S. 579 (1993) (sets federal admissibility framework for expert testimony)
Calles v. Scripto-Tokai Corp., 224 Ill. 2d 247 (2007) (Illinois endorses risk-utility integrated test for design defects)
Mikolajczyk v. Ford Motor Co., 231 Ill. 2d 516 (2008) (elements and burden in Illinois products-liability design-defect claims)
McMahon v. Bunn-O-Matic Corp., 150 F.3d 651 (7th Cir. 1998) (expert testimony must do more than state bare conclusions)
Lapsley v. Xtek, Inc., 689 F.3d 802 (7th Cir. 2012) (standard of review for district court’s Daubert/Rule 702 rulings)
Show v. Ford Motor Co., 659 F.3d 584 (7th Cir. 2011) (expert testimony often necessary when issues are outside lay knowledge)
Baltus v. Weaver Div. of Kidde & Co., 199 Ill. App. 3d 821 (1990) (some product cases may be resolvable by jurors’ common experience)