Coastal Tankship, U.S.A., Inc. v. Florence Anderson, Administratrix of the Estate of Morris Anderson
This en banc opinion addresses a personal injury suit under the Jones Act and general maritime law, where Florence Anderson sued Coastal Tankships, U.S.A., Inc. for her deceased husband Morris Anderson's bronchiolitis obliterans organizing pneumonia (BOOP), allegedly caused by naphtha exposure. The primary issue on appeal was whether the trial court abused its discretion in allowing Anderson's medical expert, Dr. David Miller, to testify on medical causation. The court found that Dr. Miller's differential diagnosis could only reliably establish specific causation, not general causation (i.e., whether naphtha can generally cause BOOP). As the record lacked reliable general-causation evidence, the appellate court concluded there was insufficient evidence to support the jury's verdict. Consequently, the judgment of the trial court was reversed, and judgment was rendered in favor of Coastal Tankships, U.S.A., Inc.