SUPREME COURT · 199702 / 55

General Electric Co. v. Joiner

General Electric Co. v. Joiner, 522 U.S. 136 (1997). Decided in Supreme Court of the United States.

COURT: Supreme Court of the United States
DECIDED: 1997
CITATION: 522 U.S. 136
OUTCOME: Excluded
STANDARD: Daubert / Rule 702
CITED BY: 4,608 later opinions (CourtListener)

THE HOLDING

Abuse of discretion is the standard of review for a Rule 702 admissibility ruling, and the district court did not abuse its discretion in excluding the plaintiff's causation experts.

EXCLUDED

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READ THE OPINIONGeneral Electric Co. v. Joiner, 522 U.S. 136↗

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On this page

The court's reasoning
From the opinion
Grounds argued
Practice note
Terms used on this page
Rulings on the same grounds

The court’s reasoning

The Court rejected more searching appellate review of exclusions, holding that Daubert did not alter the ordinary deference owed to evidentiary rulings. It also rejected the argument that a court may examine only methodology and never conclusions: conclusions and methodology are not entirely distinct, and a court may find the analytical gap between the underlying data and the opinion offered too great to bridge.

From the opinion

“nothing in either Daubert or the Federal Rules of Evidence requires a district court to admit opinion evidence that is connected to existing data only by the ipse dixit of the expert.”
General Electric Co. v. Joiner, 522 U.S. 136 (1997)

Grounds argued

This ruling turned on 2 of the eight arguments that recur across the docket. Each is defined the same way on every entry, so the same ground can be followed across rulings that reached opposite results.

Ipse dixit: Whether the opinion is connected to the underlying data by anything more than the expert's own assertion. Named for the phrase in General Electric Co. v. Joiner, this is the ground that catches conclusions the report never shows its work for.
Methodology: Whether the steps the examiner took are a recognised way of answering the question asked, and whether they were followed as described. Most digital-forensics rulings turn on this rather than on anything the field would call science.

Practice note

Practice note — our reading, not the court’s

EDITORIAL. THIS PARAGRAPH IS NOT PART OF THE HOLDING AND WAS NOT SAID BY THE COURT.

Joiner is the reason the inferential chain in a forensic report has to be written out step by step. An examiner who states that an artifact was observed and then states what the user intended has left an analytical gap; the fix is to say what the artifact establishes, what it is consistent with, and what it does not establish, in that order, so that no step rests on the examiner's say-so alone.

Everything above this panel — the holding, the reasoning, the quoted line — is a report of what the court decided and can be checked against the linked opinion. This paragraph is our own judgement about what a testifying examiner should do differently, and it should be cited as that or not at all.

Terms used on this page

Every term below is defined in the forensic glossary — what it is, why a case turns on it, and what happens in the matter when it is mishandled.

One ruling is not a rule. These are the other entries in the docket argued on the same grounds, most-cited first — including the ones that came out the other way, which are the ones worth reading before relying on this entry for anything.

ON IPSE DIXIT

United States v. Noel 581 F.3d 490 (2009) EXCLUDED
United States v. Owens 18 F.4th 928 (2021) ADMITTED
United States v. Dillingham 320 F. Supp. 3d 809 (2018) EXCLUDED
Synergeering Group v. Jonatzke 478 B.R. 846 (2012) ADMITTED IN PART

ON METHODOLOGY

Daubert v. Merrell Dow Pharmaceuticals 509 U.S. 579 (1993) ADMITTED
Kumho Tire Co. v. Carmichael 526 U.S. 137 (1999) EXCLUDED
Wellogix v. Accenture 716 F.3d 867 (2013) ADMITTED
United States v. Chiaradio 684 F.3d 265 (2012) ADMITTED

THIS ARGUMENT IN YOUR MATTER

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Attorney advertising / expert services. Each entry summarises a decision as it appeared in the opinion linked from that entry, on the day the entry was written. Decisions are reversed, vacated, superseded, and distinguished, and the text of Federal Rule of Evidence 702 was itself amended effective 1 December 2023 — check the current status and subsequent history of any ruling before relying on it. Nothing here is legal advice, none of it is a prediction about how any court will rule, and it is not a substitute for the rules, standing orders and case law of your own forum.