Easum v. Miller
Wyoming Supreme Court
92 P.3d 794, 2004 WY 73 (2004)

- Written by Joe Cox, JD
Facts
Jeff Easum (plaintiff) was a dairy farmer who suffered numerous electrical shocks and was ultimately diagnosed with reflex sympathetic dystrophy (RSD) caused by electrical injury. Easum’s illness arose soon after Prime Power and Communications, LLC (Prime Power), owned by Clay Miller (defendant), placed an electrical transformer near Easum’s farm and left an unconnected neutral line that caused stray voltage in and around the dairy. Easum ultimately sued Miller for both property damage and personal injuries. The property damage claim was settled, but a trial court dismissed the personal-injury claims on Prime Power’s motion for summary judgment. Prime Power argued that Easum’s expert witness, a neurologist named Dr. Hooshmand, must not be allowed to use differential diagnosis to testify in regard to Easum’s injuries. Dr. Hooshmand had subjected Easum to 14 days of thorough diagnostic testing and, by ruling out other causes through differential diagnosis, concluded that Easum’s RSD was caused by exposure to low levels of electrical current. Although Dr. Hooshmand had treated 13 other dairy farmers under similar situations, Dr. Hooshmand’s theories and conclusions were not supported by publication and review, and, as ethical rules would not allow electrocuting humans for clinical trials, the conclusions could not be scientifically reviewed. Those hurdles convinced the trial court, which ruled that the scientific methodology to find that low levels of electrical current could cause RSD was inadequate and rendered Dr. Hooshmand’s testimony unreliable. The trial court granted summary judgment to Miller, and Easum appealed.
Rule of Law
Issue
Holding and Reasoning (Golden, J.)
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