Studies relied upon by experts must give adequate basis for the expert’s opinion that the types of chemicals plaintiffs were exposed to in their marine employment can cause their particular injuries in the general population. During their employment, plaintiffs alleged they were exposed to various chemicals, including benzene. One was diagnosed with Hodgkin’s lymphoma and the other plaintiff was later diagnosed with bladder cancer.

Both plaintiffs asserted that benzene exposure caused their medical conditions. Plaintiffs relied on a highly qualified epidemiologist/physician as their expert witness. The witness testified that benzene exposure caused plaintiffs’ medical conditions and stated that he relied on more than 50 studies for this conclusion.

After reviewing each of the studies, the trial judge found that most of them failed to isolate benzene as the cause of the conditions and found that the remaining studies were statistically insignificant. The judge then granted defendant’s motion for summary judgment. On appeal, the court held that the trial judge did not abuse his discretion. Knight v. Kirby Inland Marine, Inc., No. 06-60134 (5th Cir., Mar. 19, 2007).