In United Fire & Casualty Co. v. Whirlpool Corp., 704 F.3d 1338 (11th Cir. 2013) (No. 11-15011), the plaintiff insurer brought this appeal from the decision of the district court that its proffered expert on the issue of whether defendant’s dryer started a fire that burned down the insureds’ house failed to satisfy the Daubert standard. The Eleventh Circuit held that although plaintiff’s fire investigator did not provide a strong theory of how the fire started (and, as a result, his opinion as to that issue was properly excluded), the trial court erred by excluding that expert’s opinion concerning where the first started. Where the fire started was the result of an investigation conducted in accordance with the National Fire Protection Association guidelines, and therefore, testimony concerning that investigation satisfied Daubert. Consequently, the appellate court reversed the summary judgment the district court had entered for defendant, and remanded the case for further proceedings at which the expert’s testimony would be admitted.