26 N.Y.2d 413 (1970)

An expert witness is not required to provide the technical reasons or bases for their opinion during direct examination; these details can be explored during cross-examination.

Summary

In a personal injury case, the plaintiff sued after a skiing accident allegedly caused by malfunctioning rented ski equipment. The Appellate Division reversed a jury verdict in favor of the plaintiff, arguing that the plaintiff’s expert failed to provide a sufficient technical foundation for their opinion. The New York Court of Appeals reversed, holding that an expert is not required to give the technical reasons for their opinion on direct examination; this can be explored on cross-examination. The court found that the hypothetical question posed to the expert contained facts fairly inferable from the evidence and that any perceived incompleteness could have been addressed during cross-examination.

Facts

The plaintiff, a novice skier, rented ski equipment from the defendant. After an employee helped him secure the boots and skis, the plaintiff proceeded down a slope towards a tow line. Shortly after starting his descent, he fell and fractured his right femur. The plaintiff’s expert testified that the injury was caused by a malfunction in the ski bindings, which should have released during the fall. The expert described the safety release mechanisms and how they protect skiers from injury.

Procedural History

The plaintiff sued the defendant for negligence, alleging that the ski equipment malfunctioned. The trial court entered judgment on a jury verdict for the plaintiff. The Appellate Division reversed the judgment, dismissing the complaint on the grounds that the plaintiff’s expert testimony was insufficient to establish negligence. The plaintiff appealed to the New York Court of Appeals.

Issue(s)

Whether an expert witness must provide the technical reasons or bases for their opinion during direct examination to establish a prima facie case of negligence.

Holding

No, because under CPLR 4515, an expert need not give technical reasons or bases for their opinion on direct examination; the matter may be left for development on cross-examination. If the facts in the hypothetical question are fairly inferable from the evidence, the expert may state their opinion without further foundation.

Court’s Reasoning

The court reasoned that the rule governing expert testimony under the CPLR does not require an expert to provide technical reasons or bases for their opinion on direct examination. The court stated, “An expert need not give technical reasons or bases for his opinion on direct examination. The matter may be left for development on cross-examination.” The court emphasized that the extent to which an expert elaborates on the technical basis of their opinion affects only the weight of the testimony, not its admissibility. The court found that the hypothetical question presented to the expert included facts of the accident and that if the defendant considered it incomplete, they could have explored the issue on cross-examination. Regarding the expert’s qualifications, the court noted that no objection was made and that the trial court’s decision to allow the testimony was not unreasonable. Judges Scileppi and Jasen dissented, arguing that the expert’s testimony was too speculative to support a finding that the ski mechanism was defective.