Kumho Tire Company, Ltd. v. Carmichael

Patrick Carmichael (plaintiff) was driving a minivan when a tire manufactured by Kumho Tire Company (defendant) blew out, killing one passenger and injuring others; Carmichael sued alleging the tire was defective. His engineering expert, Dennis Carlson, testified he could distinguish defect-caused blowouts from abuse-caused ones based on four symptoms of tire abuse, at least two of which he said must be present to indicate abuse; Carlson found all four symptoms present in his inspection but not to a significant degree, and concluded the blowout resulted from a defect rather than abuse. Kumho sought to exclude Carlson's testimony under the preliminary reliability test from Daubert v. Merrell Dow Pharmaceuticals, and the district court agreed, finding Carlson's methodology unreliable; the Eleventh Circuit reversed, and the Supreme Court granted certiorari.