Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (1999)
Kumho Tire v. Carmichael is the Supreme Court's companion to Daubert and Joiner that completes the modern framework for admitting expert evidence under Federal Rule of Evidence 702.
Does Daubert's reliability-based gatekeeping requirement under Federal Rule of Evidence 702 apply to all expert testimony, including technical and experience-based expertise, and did the district court abuse its discretion in excluding the plaintiffs' tire-failure expert?
Under Federal Rule of Evidence 702, the trial judge acts as a gatekeeper to ensure that any expert testimony—scientific, technical, or other specialized knowledge—is relevant and reliable. The reliability inquiry is a flexible one; Daubert's factors (testing, peer review/publication, known or potential error rate, standards/controls, and general acceptance) may be considered where appropriate but are not a mandatory or exhaustive checklist. Trial courts have broad discretion in both selecting the appropriate reliability factors for the discipline at issue and in deciding whether to admit or exclude expert evidence. Appellate review of such determinations is for abuse of discretion.
Yes. Daubert applies to all expert testimony within Rule 702, including technical and experience-based expertise. The district court did not abuse its discretion in excluding the tire-failure expert's testimony as unreliable and in granting summary judgment for Kumho.
Kumho cements that Daubert governs all expert testimony under Rule 702, eliminating any carve-out for engineering or experience-based experts. It instructs judges to tailor reliability analysis to the discipline while insisting on demonstrable methodological reliability, not mere credentials or ipse dixit. The case also confirms abuse-of-discretion review for admissibility decisions, giving district courts considerable control over the expert evidence that reaches juries. For law students and litigators, Kumho is pivotal: it guides how to build a record of reliability for experience-based experts (by showing testing, standards, validation, or reliable professional practice) and how to challenge such experts when their methods are untested, standardless, or inconsistently applied.