Pyramid Tech. v. Hartford Cas. Ins. Co.

Expert testimony that meets the standards of the Federal Rules of Evidence is admissible in court for a trier of fact to determine its correctness so long as a court deems the opinions to be based on sound methodology and relevant principles within the expertise of the aficionado.

Pyramid Technologies, Inc. (“Pyramid”) was storing older electronic parts in a warehouse. Pyramid purchased insurance from Harford Casualty Insurance Company (“Hartford”) with the foresight to cover replacement costs for their business, buildings, and electronic parts if ever needed. The building later flooded and there was some condensation found on some of the bags that were storing some of the electronic devices. Pyramid then contacted their insurance carrier to report the problem, but Harford’s expert stated that there was no water damage, and that Pyramid could not collect on the policy. As a result, Pyramid hired experts to testify to the contrary. The district court excluded all of Pyramid’s expert witness testimony, reasoning that the experts were not qualified and had no plausible explanation, making them unreliable. The Ninth Circuit reviewed the expert testimony for admissibility and reliability in order to determine if each of the three experts that Pyramid called where satisfactory. The panel determined that both admissibility and reliability were based on factor tests and that the trial court was to act as a gatekeeper in order to determine whether the information should be entered into court, but not necessarily whether the experts were correct in their assertions because a jury is the ultimate trier of fact. As a result, the panel found two of the three experts that Pyramid called to testify to be admissible in court. Additionally, the panel found that a jury could reasonably infer that damage did, in fact, take place, and that it could logically be connected to the flood based on the theory of “efficient proximate cause.” AFFIRMED in part, REVERSED in part, and REMANDED for trial.