In Hanshaw v. Crown Equipment Corp., the Missouri Supreme Court affirmed the circuit court’s exclusion of the plaintiff’s expert witness and the grant of summary judgment for the defendant. Hanshaw alleged the forklift he operated was defectively designed, but his expert failed to demonstrate that his opinions were based on reliable methodology, testing, or peer-reviewed research as required under section 490.065. The Court emphasized that expert testimony must be grounded in demonstrable principles and methods, not merely personal observations or unsupported conclusions. Without admissible expert evidence, no genuine issue of material fact existed, and Hanshaw’s claims—including punitive damages—could not survive summary judgment.
In a recent decision from the Missouri Supreme Court, Christopher Hanshaw’s appeal challenging the exclusion of his expert witness and the subsequent summary judgment in favor of Crown Equipment Corporation was denied. See, Christopher Hanshaw, Appellant, vs. Crown Equipment Corp., et al., SC101091. The case arose from a 2016 forklift accident, in which Hanshaw alleged the forklift was defectively designed, particularly criticizing its open operator compartment. Hanshaw retained an expert to testify that the forklift was unreasonably dangerous and could be made safer through the addition of a door or bumper. Crown Equipment moved to exclude the expert and sought summary judgment, arguing that the expert lacked qualifications, employed unreliable methodology, and provided opinions amounting to mere speculation.
The circuit court excluded Hanshaw’s expert, finding that the expert failed to demonstrate that his opinions were based on reliable methods. Although the expert claimed to rely on personal observations, accident reports, OSHA data, and prior analyses, the court concluded that he did not show how this information supported his conclusions. The court specifically noted the absence of testing, peer review, or any methodological framework to substantiate the expert’s alternative design proposals. On this basis, the court ruled that the expert’s testimony did not meet the reliability standard under Missouri Revised Statutes § 490.065, which requires that expert testimony be grounded in sufficient facts or data, employ reliable principles and methods, and be properly applied to the case.
The Missouri Supreme Court affirmed the circuit court’s decision, emphasizing that admissibility of expert testimony under section 490.065 requires more than an expert’s qualifications or personal observations. The Court explained that reliability must focus on the methodology and principles underpinning the expert’s conclusions, not merely the conclusions themselves. The Supreme Court furthered stressed that courts may exclude expert opinions when there is an analytical gap between the data presented and the opinion offered, particularly where no testing, peer review, or demonstrable methodology supports the expert’s conclusions. In this case, Hanshaw’s expert failed to establish such a reliable connection, leaving no admissible evidence to support his claims.
Without the expert’s testimony, the Court found no genuine issue of material fact to prevent summary judgment. The Court also noted that Hanshaw’s claim for punitive damages could not survive independently, as punitive damages require an underlying successful liability claim. Accordingly, the Missouri Supreme Court affirmed the circuit court’s ruling, reinforcing the principle that exclusion of expert testimony under section 490.065 is reviewed for abuse of discretion and highlighting the necessity for experts to demonstrate reliable methodology and proper application of their principles to the facts at hand.
The Hanshaw decision underscores the critical importance for lawyers and adjusters to rigorously evaluate the methodological foundation of any proposed expert testimony at the earliest stages of a case. Missouri courts, applying § 490.065, continue to demand that experts articulate not only their opinions but the reliable, testable, and peer‑recognized principles and methods supporting those opinions. Personal observations, experience alone, or references to general industry materials are not enough without a demonstrable analytical connection to the conclusions offered. In practice, this means counsel should ensure that retained experts can clearly explain the testing, research, data analysis, and methodological framework underlying their opinions—and be prepared to defend those foundations in a Daubert-style reliability challenge. Likewise, adjusters should assess the strength of an expert’s methodology when evaluating claim exposure, recognizing that claims relying on speculative or unsupported expert assertions may not survive summary judgment. By scrutinizing reliability early, legal teams can better anticipate admissibility issues, strengthen defensible claims, and avoid the risk of a case collapsing due to exclusion of key expert evidence.