Adams, et al. v. Laboratory Corp. of America, No. 13-10425 (11th Cir. 2014)Annotate this Case
Plaintiff and her husband filed suit against LabCorp, alleging that its cytotechnicians were negligent in failing to identify abnormalities in plaintiff's Pap smears and that this negligence caused a delay in her cancer diagnosis. The district court granted LabCorp's motion to exclude plaintiff's expert's testimony based on its conclusion that her methodology did not meet the reliability requirements under Federal Rule of Evidence 702. The district court then granted LabCorp's motion for summary judgment. The court concluded, however, that the expert was qualified to testify about cytotechnologists' standard of care, her methodology was reliable, and her testimony would assist the trier of fact. Therefore, the district court abused its discretion in excluding her testimony. The court reversed in part, vacated in part, and remanded for further proceedings.