Christophersen v. Allied-Signal Corp.

1992-03-02
Share:

Headline: Justices declined to review a dispute over the rule for admitting expert testimony about workplace toxic exposure, leaving appeals courts divided and the family’s claim unresolved for now.

Holding: The Supreme Court declined to review the case, leaving in place lower-court disagreement over whether expert testimony must be generally accepted to be admissible.

Real World Impact:
  • Leaves a split among federal appeals courts about admitting expert scientific testimony.
  • Keeps lower-court decisions and this family’s case unchanged for now.
  • Maintains uncertainty for litigants about what expert evidence courts will allow.
Topics: expert testimony, scientific evidence standards, workplace toxic exposure, court splits

Summary

Background

Albert Roy Christophersen died of a rare cancer in 1986. His widow and son sued, saying fumes from nickel/cadmium battery manufacture at his workplace caused the illness. They relied on opinions from an internist and a toxicologist. The defendants argued the experts had no reliable basis for their views. The federal district court agreed that the doctor’s affidavit lacked the usual evidence relied on by cancer researchers and entered judgment for the defendants. A Court of Appeals panel reversed, but the full Fifth Circuit sitting en banc later affirmed the district court’s judgment.

Reasoning

The central question is what standard courts should use to decide whether scientific expert testimony is reliable enough to be admitted. Eight judges on the Fifth Circuit relied in part on an older rule that allows expert evidence only if the expert’s methods are generally accepted in the scientific community. Five judges on that court rejected that test. Other federal appeals courts are also split: some apply the general-acceptance approach, while others treat the Federal Rules of Evidence as setting a different, lower threshold.

Real world impact

Because the Supreme Court refused to take the case, the split among appeals courts continues. That means different federal courts may apply different tests when deciding whether to admit expert scientific evidence. The company’s win in the district court stands for now, and the family’s case remains without a Supreme Court decision.

Dissents or concurrances

Justice White, joined by Justice Blackmun, dissented from the Court’s refusal to review the case and said he would grant review to resolve the recurring conflict among appeals courts.

Ask about this case

Ask questions about the entire case, including all opinions (majority, concurrences, dissents).

What was the Court's main decision and reasoning?

How did the dissenting opinions differ from the majority?

What are the practical implications of this ruling?

Related Cases