Legal Memorandum: Standard of Review in Admission of Expert Testimony

Issue: Under federal law, what standard of review does an appellate court apply when reviewing whether a district court properly admitted expert testimony?

The Circuit Court has plenary review of a district court’s application and interpretation of Fed. R. Evid. 702 but reviews the district court’s decision to admit or exclude expert testimony under an abuse of discretion standard.  Oddi v Ford Motor Co., 234 F.3d 136, 146 (3d Cir. 2000).  “An abuse of discretion arises when the district court’s decision ‘rests upon a clearly erroneous finding of fact, an errant conclusion of law or an improper application of law to fact.’"  Id. (citing Hanover Potato Prods., Inc. v. Shalala, 989 F.2d 123, 127 (3d Cir. 1993)).  An abuse of discretion can also occur “when no reasonable person would adopt the district court’s view.”  Id. (citing Hanover, 989 F.2d at 127).  The Third Circuit will reverse a district court’s exercise of discretion if it has “a definite and firm conviction that the court below committed a clear error of judgment in the conclusion it reached upon a weighing of the relevant factors.”  Id.

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