Hendrix ex rel. G.P. v. Evenflo Co.
United States Court of Appeals for the Eleventh Circuit
609 F.3d 1183 (2010)
- Written by Eric Miller, JD
Facts
A child carrier manufactured by Evenflo Company, Inc. (defendant) fractured in a minor automobile accident. G.P., a baby boy, sustained a head injury in the accident. Approximately a year and a half later, G.P. was diagnosed with a spinal-cord cyst. G.P.’s mother, Rhonda Hendrix (plaintiff), alleged that a manufacturing defect in the baby carrier caused the head injury, and that the injury caused G.P. to develop autism spectrum disorder and the spinal-cord issue. Hendrix sued Evenflo in federal district court under diversity jurisdiction, with Florida law governing standards of causation and federal law governing standards of evidence. The parties disagreed over the severity of G.P.’s injuries and the relationship between the accident and G.P.’s later developmental problems. Hendrix sought to admit the expert testimony of a pediatric neurologist in the form of differential etiology, a medical process of elimination in which the possible causes of a condition are ruled out one at a time, leaving a single cause. The court excluded the testimony, finding it inadequate to support a theory of causation. Partial summary judgment was granted in favor of Evenflo. Hendrix appealed. The United States Court of Appeals for the Eleventh Circuit granted certiorari.
Rule of Law
Issue
Holding and Reasoning (Anderson, J.)
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