Johnson v. Mead Johnson & Co., No. 13-1685 (8th Cir. 2014)
Annotate this CasePlaintiff, guardian ad litem for minor H.T.P., appealed the district court's adverse grant of summary judgment in this products liability case. Plaintiff alleged that Enfamil, an infant formula, was defective or unreasonably dangerous due to C.sak contamination. On appeal, plaintiff argued that the district court abused its discretion in refusing to allow its experts' testimony under Rule 702. The court concluded that the district court abused its discretion in excluding plaintiff's experts where the methodology employed by the experts was scientifically valid, could properly be applied to the facts of the case and was therefore reliable enough to assist the trier of fact. With the expert testimony proposed, plaintiff has created an issue of fact for a jury on the issue of the specific cause of H.T.P.'s C. sak infection and plaintiff was entitled to attempt to prove his claim for products liability under Minnesota law. Accordingly, the court reversed the orders of the district court excluding the testimony of plaintiff's experts, and granting summary judgment and costs in favor of Mead, and remanded for further proceedings.
Court Description: Civil Case - Products liability. In an action alleging plaintiffs' infant child suffered severe permanent brain damage as a result of using contaminated Enfamil formula manufactured by defendant, the district court erred in excluding plaintiff's experts as their methods for ruling in and then excluding possible causes was scientifically valid and sufficiently reliable to assist the trier of fact; with the expert testimony, plaintiff has created an issue of fact for the jury on the issue of specific cause of the infant's C. sak infection and is entitled to attempt to prove the claim pursuant to Minnesota law.
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