YOUNG v. JABIL, INC.
2:23-cv-04992
E.D. Pa.May 19, 2025Background
- Plaintiff Maurice Young, a former Machine Operator at Jabil, Inc., suffers from osteoarthritis limiting his ability to work.
- After two leaves of absence for medical reasons, Young sought to return to work with accommodation; he submitted medical paperwork late and requested multiple accommodations, including transfer to another position.
- Jabil stated it could not accommodate Young and terminated his employment on November 1, 2022, after rejecting his transfer request.
- Young then applied for another internal position before his termination but was not placed in that role.
- Plaintiff’s expert, Dr. John Dieckman, produced a report on vocational ability and loss of earnings, which Jabil challenged via a Daubert motion to exclude the expert's testimony.
- The district court reviews the Daubert challenge under Federal Rule of Evidence 702, focusing on qualifications, reliability, and fit.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Expert Qualification (ADA) | Dieckman is qualified as a vocational expert | Dieckman lacks necessary medical and ADA expertise | Dieckman is qualified; broad expertise is sufficient |
| Expert Qualification (Econ Loss) | Vocational expertise is sufficient for wage loss claims | No formal economics/business credentials | Dieckman is qualified to assess economic loss |
| Reliability of Methodology | Methodology is based on record review & accepted basis | Unreliable: based on late or irrelevant data, not thorough | Dieckman used sufficiently reliable methodology |
| Fit/Relevance | Testimony will assist trier of fact | Opinions are speculative and unhelpful | Testimony fits the issues; aids the jury's determination |
Key Cases Cited
- Elcock v. Kmart Corp., 233 F.3d 734 (3d Cir. 2000) (discusses standards for vocational expert qualification and methodology)
- In re Paoli R.R. Yard PCB Litig., 35 F.3d 717 (3d Cir. 1994) (outlines reliability factors under Daubert)
- Pineda v. Ford Motor Co., 520 F.3d 237 (3d Cir. 2008) (liberal admissibility standard for experts under Rule 702)
- Kannankeril v. Terminix Int’l, Inc., 128 F.3d 802 (3d Cir. 1997) (sets out standards for admissibility of expert testimony)
- Waldorf v. Shuta, 142 F.3d 601 (3d Cir. 1998) (discusses liberal interpretation of expert qualifications)