Utah Court of Appeals

Can competing expert opinions defeat summary judgment in product liability cases? Best v. Daimler Chrysler Corporation Explained

2006 UT App 304
No. 20050225-CA
July 20, 2006
Reversed

Summary

Plaintiff sued defendants for a defective airbag that deployed unexpectedly, causing injury. The trial court granted summary judgment after defendants’ expert concluded improper steering repairs caused the deployment, while plaintiff’s expert attributed it to defective parts. The court of appeals reversed, finding the competing expert theories created genuine factual disputes.

Analysis

In Best v. Daimler Chrysler Corporation, the Utah Court of Appeals addressed whether competing expert opinions on the cause of an airbag malfunction precluded summary judgment in a product liability case. The decision provides important guidance on when expert disagreements create genuine issues of material fact.

Background and Facts
Plaintiff purchased a used 1993 Chrysler that was involved in two accidents requiring repairs using aftermarket parts. In 1999, the driver’s airbag deployed unexpectedly while driving in a parking lot, allegedly injuring plaintiff. Defendants’ expert concluded that improper steering repairs caused clockspring damage, leading to a short circuit and premature deployment. Plaintiff’s expert disagreed, attributing the malfunction to defective airbag components based on diagnostic readouts and photographs, without conducting a physical inspection.

Key Legal Issues
The court addressed two primary issues: (1) whether competing expert methodologies and conclusions created genuine issues of material fact precluding summary judgment, and (2) whether the trial court properly allowed plaintiff to substitute expert witnesses after the original expert became unavailable.

Court’s Analysis and Holding
The court of appeals reversed the summary judgment, emphasizing that it is not the purpose of summary judgment to judge witness credibility or weigh evidence. The court found that plaintiff’s expert sufficiently disputed defendants’ conclusions about both the proper diagnostic method and the source of the defect. Regarding the diagnostic methodology, the court noted that determining whether physical inspection was necessary would require weighing expert opinions, which is reserved for the fact finder. The expert’s explanation for apparent contradictions between his deposition and affidavit testimony was adequate to avoid disregarding the affidavit.

Practice Implications
This decision reinforces that competing expert opinions typically preclude summary judgment, even when experts disagree on methodology. Practitioners should ensure expert affidavits provide sufficient factual basis rather than mere conclusions. When expert testimony appears contradictory, adequate explanations for discrepancies between depositions and affidavits can preserve the testimony’s viability. The court’s broad discretion regarding expert witness substitutions also demonstrates the importance of properly designating experts initially while recognizing that courts may allow substitutions to advance case resolution.

Original Opinion

Link to Original Case

Case Details

Case Name

Best v. Daimler Chrysler Corporation

Citation

2006 UT App 304

Court

Utah Court of Appeals

Case Number

No. 20050225-CA

Date Decided

July 20, 2006

Outcome

Reversed

Holding

Summary judgment was improper where competing expert opinions on airbag defect diagnosis and causation created genuine issues of material fact.

Standard of Review

Summary judgment reviewed for correctness; expert witness substitution reviewed for correctness with broad discretion afforded to trial court

Practice Tip

When opposing summary judgment with expert testimony, ensure your expert provides adequate explanation for any apparent contradictions between deposition testimony and affidavits to avoid having the affidavit disregarded.

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