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PA Court Rejects Testimony Based on Expert’s Belief Rather Than Science

In a decision clarifying the threshold for admissible expert testimony regarding causation, a Pennsylvania court affirmed that a plaintiff’s expert must rely on a scientific basis, not simply his own subjective beliefs, to testify regarding a causal relationship between chemical exposure  and cancer. Snizavich v. Rohm & Haas Co., No. 1383 EDA 2012 (Pa. Super. Ct. Dec. 6, 2013). 

Following her husband’s death from brain cancer, Plaintiff filed suit alleging the cancer was caused by exposure to chemicals from working at Defendant’s facility.  Snizavich, slip op., at 2. Defendant filed a motion for summary judgment arguing that Plaintiff’s expert testimony was not adequate to prove causation. Id. The trial court granted Defendant’s motion, finding the testimony did not meet the basic admissibility requirements for expert testimony. Id. at 4. 

The Court found that, to be admissible as expert testimony, the opinions must be based in scientific authority that the expert applies to the facts. Id. at 10. Because Plaintiff’s expert relied solely on his own subjective beliefs, and not any scientific authority, Plaintiff’s expert failed to meet this threshold, and the Court affirmed the trial court’s ruling that the testimony was not admissible. Id. at 11.