General Electric Co. v. Joiner: lighting up the post-Daubert landscape

Abstract

The U.S. Supreme Court considered an appeal by the defendant, General Electric Co., in a products liability action. The appeal resulted from the ruling by the Court of Appeals for the Eleventh Circuit that overturned the district court's exclusion of evidence of cancer causation. The Supreme Court held that questions of the admissibility of such evidence are reviewable under the same standard--abuse of discretion--as are other decisions regarding evidentiary issues and are not subject to a more stringent standard of review. The Court further held that whether or not the evidence is excluded or is dispositive of the case does not change this standard of review. The Court then examined and upheld the decision by the trial court rather than remanding the action to the circuit court for reconsideration in light of the decision. Coupled with a series of recent circuit court of appeals decisions, the case establishes some guidance for the basis and methodology to be used to admit social science evidence in future cases.