Huggins v. Siegel
Tenants sued their landlord alleging that toxic mold exposure during pregnancy caused their child's renal agenesis and brain injury. The trial court granted the landlord's Daubert motion excluding the plaintiffs' causation expert (a reproductive endocrinologist) and then entered summary judgment. The First DCA affirmed, holding the Daubert motion was timely because it was filed within the pretrial scheduling order deadline and the plaintiffs showed no prejudice (they never sought a continuance to obtain a replacement expert), and that abuse of discretion—not de novo—is the standard of review for Daubert rulings.
Key facts
- Tenants sued their landlord alleging that toxic mold exposure during the mother's pregnancy caused their child's renal agenesis and brain injury.
- The trial court granted the landlord's Daubert motion excluding the plaintiffs' causation expert, a reproductive endocrinologist, and entered summary judgment for the defendant.
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Why it matters
Practitioners defending or prosecuting toxic-tort and causation-heavy cases can use this opinion for two points: Daubert motions are timely if filed within the pretrial scheduling order deadline even long after the… — full analysis with a trial
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