Medical malpractice; Expert admissibility; MRE 702; Danhoff v Fahim; Reliability of expert methods; MCL 600.2955; Edry v Adelman; Daubert gatekeeping; Chapin v A & L Parts, Inc; Competing expert interpretations

The court held that the trial court abused its discretion by excluding plaintiff’s family-medicine expert under MRE 702. Decedent went to the ER in 2016 with breathing difficulty, and a CT showed “focal airspace consolidation” with differential considerations including “pulmonary infarct or focal pneumonia.” He was treated for pneumonia, improved within days, and later was diagnosed with lung cancer “in the same area” about two years later and died. The trial court granted defendants summary disposition after excluding plaintiff’s only standard-of-care expert, Dr. T, reasoning his opinion was unreliable because he relied on experience and “common sense” and the literature did not support him. On appeal, the court held that the trial court’s reliability analysis improperly treated the Daubert hearing as “a judicial search for truth,” and reiterated that a court’s gatekeeping role is “to filter out expert evidence that is unreliable,” not to “admit only evidence that is unassailable,” because “the courts are not in the business of resolving scientific disputes.” The court also concluded other materials were enough to show Dr. T’s view was “rationally derived from a sound foundation,” even if defendants’ experts “value[d] the available research differently” and “ascribe[d] different significance to that research.” Because Dr. T’s testimony was admissible, plaintiff was not left without expert proof on the standard of care, and the summary disposition order could not stand. Reversed and remanded.