Scapa Dryer Fabrics, Inc. v. KnightAnnotate this Case
Scapa Dryer Fabrics, Inc. was a textile manufacturer, and in the late 1960s and early 1970s, it produced dryer felts at a manufacturing facility in Waycross. Some of the pipes and boilers in that facility were insulated with material containing asbestos, and Scapa used yarn containing asbestos in some of its manufacturing processes. Between 1967 and 1973, Roy Knight worked on multiple occasions at the Waycross facility as an independent contractor. Almost forty years later, Knight was diagnosed with mesothelioma. After his mesothelioma was diagnosed, Knight and his wife sued Scapa, claiming that Scapa negligently exposed him to asbestos at the Waycross facility and caused his mesothelioma. The case was tried in front of a jury, which returned a verdict against Scapa and awarded more than $4 million in damages to the Knights. The trial court entered a judgment upon that verdict, and Scapa appealed. At trial, the Knights bore the burden to establish not only that one of their experts, Dr. Abraham, was qualified and that his testimony was reliable, but also that his testimony would be helpful to the jury. His ultimate opinion as to causation, however, was not limited to any meaningful estimate of exposure to asbestos at the Waycross facility (whether qualitative or quantitative), and it instead invited the jury to find that causation was established by any exposure at all. In that respect, the Supreme Court concluded the testimony did not “fit” the pertinent causation inquiry under Georgia law, and it should have been excluded by the trial court, acting as gatekeeper, because it could only serve to confuse the jury on the issue of causation. "And given that Dr. Abraham’s opinion 'went to the heart' of the dispute about the extent of exposure and causation, 'the erroneous admission of the opinion requires that we reverse the Court of Appeals’ affirmance of the trial court’s judgment.'"