Ruffin v. BP Exploration & Production, Inc.

Floyd Ruffin (plaintiff) spent five months cleaning up crude oil from the 2010 Deepwater Horizon spill. During that work, Ruffin had direct contact with the crude oil twice—once when oil splashed on him and once when he fell into oil-contaminated water. Ruffin also claimed he routinely inhaled strong petroleum fumes while working. Five years later, Ruffin was diagnosed with prostate cancer. Ruffin brought a toxic-tort claim against BP Exploration & Production, Inc. (BP) (defendant) in federal district court, alleging that his crude-oil exposure had triggered his genetic precondition to prostate cancer. To prove causation, Ruffin offered expert testimony from epidemiologist Dr. Benjamin Rybicki. Rybicki’s stated opinion was that Ruffin had been exposed to polycyclic aromatic hydrocarbons (PAHs) in the crude oil and that these PAHs had caused Ruffin’s prostate cancer. However, Rybicki acknowledged that only one PAH, benzo(a)pyrene, was carcinogenic. Rybicki did not claim that (1) Ruffin had been exposed to benzo(a)pyrene during the cleanup or (2) benzo(a)pyrene exposure was linked specifically to prostate cancer. Similarly, the data Rybicki relied on for his offered expert opinions did not support any specific link between benzo(a)pyrene exposure and prostate cancer. BP moved to exclude Rybicki’s causation testimony under Federal Rule of Evidence 702 and the Daubert standard, arguing that these opinions were not sufficiently reliable. BP also moved for summary judgment, asserting that Ruffin could not establish causation without Rybicki’s testimony. The district court excluded Rybicki’s opinions and then granted summary judgment for BP. Ruffin appealed to the Fifth Circuit Court of Appeals.