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Bradley v. Brown

District Court, N.D. Indiana (1994) | 852 F. Supp. 690; 1994 U.S. Dist. LEXIS 6582; 1994 WL 199827

4 min read

TL;DR: An exterminator was found negligent for causing employees' immediate sickness from pesticide exposure. However, the court excluded expert testimony linking the exposure to the novel diagnosis of "multiple chemical sensitivity," finding the theory scientifically unreliable under the Daubert standard and limiting damages accordingly.

Legal Significance: This case is a significant early application of the Daubert standard, demonstrating a court's "gatekeeping" role in excluding expert testimony on novel scientific theories of causation (like multiple chemical sensitivity) that lack sufficient empirical testing, peer review, and general acceptance in the scientific community.