Kenneth McDaniel, Plaintiff-Appellee v. Csx Transportation, Inc., Defendant-Appellant

Summary

The Tennessee Supreme Court granted an interlocutory appeal to clarify the standards for admitting scientific evidence under Tenn. R. Evid. 702 and 703, and held that the 1991 adoption of those rules superseded the Frye general-acceptance test. Trial courts must act as gatekeepers, determining whether expert testimony will substantially assist the trier of fact, whether the underlying facts and data indicate a lack of trustworthiness, and whether the reasoning or methodology is scientifically valid and reliable and applicable to the facts at issue, guided by five non-exclusive reliability factors borrowed from Daubert without expressly adopting it. Applying those standards, the plaintiffs' epidemiological evidence linking chronic low-dose solvent exposure to toxic encephalopathy was admissible, and the trial court did not abuse its discretion in denying CSXT's motion in limine.