System Development Integration, LLC v. Computer Sciences Corp.
886 F. Supp. 2d 873
N.D. Ill.2012Background
- SDI sues CSC for breach of subcontract, tortious interference, fiduciary duty, quantum meruit, and equitable estoppel related to CSC replacing SDI with another vendor on an Exelon contract.
- SDI’s damages expert Mayer offers three damage theories: partnership breach, subcontract breach, and quantum meruit.
- District court held a Daubert hearing and then granted in part and denied in part CSC’s motions to exclude Mayer’s testimony.
- Court previously granted summary judgment for CSC on several claims, with some claims later remaining pending and scheduling a jury trial for 2012.
- Court excludes Mayer’s quantum meruit opinions and certain misapplications of Illinois law; allows other damages opinions to proceed with limitations and potential revisions.
- Present value calculation and timing issues are addressed; court instructs Mayer to recalculate using the proper date if necessary and to provide revised figures by a deadline.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Mayer is qualified to render damages opinions | SDI asserts Mayer’s expertise supports damages analysis | CSC challenges the relevance and reliability of Mayer’s methods | Mayer is qualified to testify as damages expert |
| Whether Mayer’s partnership-damages opinions are admissible | Partnership damages are relevant to SDI’s fiduciary-duty claim due to pre-contract effects | Partnership claim dismissed; damages on that basis irrelevant | Damages opinions tied to partnership breach excluded |
| Whether Mayer’s quantum meruit opinions are admissible | Quantum meruit damages reflect SDI’s costs and CSC’s enrichment | Opinions rest on unreliable basis; not supported by Illinois law measures | Quantum meruit opinions excluded |
| Whether Mayer’s subcontract damages are admissible, including present value/discounting and assumptions | Lost profits based on subcontract terms and incremental expenses are proper | Arguments rely on unfounded assumptions and improper present-value timing | Subcontract damages allowed with cautions; need revisions for date and assumptions; cross-examination allowed |
| Rule 403/other procedural objections | Arguments should be admitted with limitations | Evidence unfairly prejudicial; or improperly speculative | Rule 403 argument waived; court addresses merits of admissibility; not dispositive by itself |
Key Cases Cited
- Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993) (gatekeeping admissibility of expert testimony under Rule 702)
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) (Daubert applies to all expert testimony, not just science)
- Gen. Elec. Co. v. Joiner, 522 U.S. 136 (1997) (abuse of Daubert gatekeeping; appellate review of reliability/fit)
- Lapsley v. Xtek, Inc., 689 F.3d 802 (2012) (Daubert reliability; district court wide latitude in gatekeeping)
- Bielskis v. Louisville Ladder, Inc., 663 F.3d 887 (2011) (need for reliable principles and data; cross-examination allowed)
- Tri-G, Inc. v. Burke, Bosselman & Weaver, 222 Ill.2d 218, 856 N.E.2d 389 (2006) (lost profits require reasonable certainty; not conjecture)
- Chicago’s Pizza, Inc. v. Chicago’s Pizza Franchise Ltd. USA, 384 Ill.App.3d 849, 893 N.E.2d 981 (2008) (lost profits measure and reliance on pre-existing business data)