Kumho Tire Co. v. Carmichael

Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999), is a United States Supreme Court case that applied the Daubert standard to expert testimony from non-scientists.

The district court took its cue from Daubert v. Merrell Dow Pharmaceuticals, which had solidified a gatekeeping role for trial judges in admitting expert testimony.

The district court found the tire expert's methods not to be scientifically valid, and hence excluded his testimony.

It reasoned that Daubert was expressly limited only to scientific expert testimony and did not apply to "skill- or experience-based observation."

Kumho Tire asked the Supreme Court to review whether Daubert applied solely to scientific evidence.

Daubert had mentioned four factors that district courts could take into account in making the gatekeeping assessment—whether a theory has been tested, whether an idea has been subjected to scientific peer review or published in scientific journals, the rate of error involved in the technique, and even general acceptance, in the right case.

The district court acted within its discretion to exclude the evidence proffered by the tire expert in light of these concerns.