Reliability Proof Required for Expert Design-Defect Opinions Under § 490.065; Exclusion Can Compel Summary Judgment
1. Introduction
In Hanshaw v. Crown Equipment Corp. (Mo. banc Feb. 24, 2026), the Supreme Court of Missouri affirmed
summary judgment for Crown Equipment Corporation after the circuit court excluded the plaintiff’s only design-defect
expert under section 490.065. The case arose from a 2016 workplace accident in which
Christopher Hanshaw was injured while operating a Crown stand-up forklift with an
“open operator compartment” design.
Hanshaw sued Crown Equipment asserting product liability theories centered on defective design (and related warnings),
and he sought punitive damages. His theory depended on expert testimony that the forklift was unreasonably dangerous
and that adding a door or bumper would be a safer alternative design.
The core issues on appeal were (i) whether the expert’s opinions satisfied the reliability requirements of
§ 490.065.2(1)(c)-(d), and (ii) whether, without admissible expert evidence, any genuine issue of
material fact remained to defeat summary judgment.
2. Summary of the Opinion
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The Court held the circuit court did not abuse its discretion in excluding Hanshaw’s expert because
Hanshaw failed to demonstrate the expert’s opinions were the product of reliable principles and methods reliably
applied to the facts, as required by § 490.065.2(1)(c)-(d).
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With the expert excluded, the Court held summary judgment was proper because Hanshaw lacked admissible evidence
creating a genuine issue of material fact on his product liability claims.
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The Court also affirmed summary judgment on punitive damages because punitive damages are unavailable absent a
plaintiff’s success on an underlying claim for actual damages.
3. Analysis
3.1 Precedents Cited
Procedural posture and what is appealable
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Lozano v. BNSF Ry. Co., 421 S.W.3d 448, 453 n.4 (Mo. banc 2014): The Court reiterated that
a motion in limine “by itself, preserves nothing for appeal.” This framed the appeal as review of the
summary judgment rather than a free-standing review of the in limine ruling—while recognizing the expert
admissibility analysis may be embedded in (and relevant to) the summary judgment decision.
Standard of review—expert admissibility
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Linton ex rel. Linton v. Carter, 634 S.W.3d 623, 626-27 (Mo. banc 2021): The Court applied the
abuse-of-discretion standard and quoted the classic formulation—abuse occurs only when the ruling is “clearly
against the logic of the circumstances” and “shocks the sense of justice.” This high deference mattered because
Hanshaw’s showing of reliability was thin and incomplete.
Summary judgment record discipline
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Green v. Fotoohighiam, 606 S.W.3d 113, 117-18 (Mo. banc 2020): The Court emphasized that summary
judgment review is confined to the Rule 74.04(c) record, not “the whole trial court record,” and
courts need not “sift through the entire record” to find disputes. This reinforces a key practical lesson of
Hanshaw: even if helpful material exists somewhere in discovery, it must be properly placed before the court
in a usable form for the relevant motion.
Missouri’s § 490.065 and the federal Daubert framework
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Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993): The Court adopted Daubert’s core reliability
concepts and factors (testability, peer review/publication, error rate/standards, general acceptance), stressing the
court’s gatekeeping focus on “principles and methodology,” not just conclusions.
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State v. Carpenter, 605 S.W.3d 355, 361 n.4 (Mo. banc 2020): Used to explain interpretive alignment:
because § 490.065 is identical to Rule 702, federal decisions are persuasive (not binding).
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Gen. Elec. Co. v. Joiner, 522 U.S. 136, 146 (1997): Central to the Court’s reasoning. Joiner
supplies the “ipse dixit” and “analytical gap” concepts: courts need not admit opinions connected to data only by the
expert’s say-so, and may exclude opinions where the inferential bridge from data to conclusion is too large.
“Personal observations” are not a shortcut around reliability
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State ex rel. Gardner v. Wright, 562 S.W.3d 311 (Mo. App. 2018): Hanshaw relied on Gardner for the
proposition that expert testimony based on personal observation is not per se unreliable. The Court distinguished
Gardner as addressing generalized testimony by a social worker/forensic interviewer about disclosure processes—not a
technical design-defect opinion requiring demonstrated engineering methodology.
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State v. Gibbons, 629 S.W.3d 60, 85 (Mo. App. 2021): Cited as an example applying
§ 490.065.2(1) to generalized forensic-interviewer testimony, underscoring that the statute’s
requirements remain operative across expert contexts.
Summary judgment standards
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Hill v. Ford Motor Co., 277 S.W.3d 659, 664 (Mo. banc 2009): De novo review; view the record in the
light most favorable to the non-movant.
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Larabee v. Eichler, 271 S.W.3d 542, 545 (Mo. banc 2008): The “no genuine issue of material fact” and
“entitled to judgment as a matter of law” formulation.
Admissible evidence requirement at summary judgment
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L.A.C. ex rel. D.C. v. Ward Parkway Shopping Ctr. Co., 75 S.W.3d 247, 253 n.3 (Mo. banc 2002):
“Only evidentiary materials that are admissible or usable at trial can sustain or avoid summary judgment.”
This principle allowed the Court to treat exclusion of the expert as dispositive of the merits at the
summary-judgment stage.
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Rule 74.04(e): Affidavits must set forth facts admissible in evidence, reinforcing the admissibility
filter at the summary judgment stage.
Timing and inability to “fix” the expert after exclusion
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Rhoden v. Mo. Delta Med. Ctr., 621 S.W.3d 469, 484 (Mo. banc 2021): Cited for the practical point
that when discovery has closed, it may be too late to endorse a new expert or cure defects—even though exclusion
rulings are typically interlocutory. This supports the case-management consequence: reliability deficiencies can
become case-ending once deadlines pass.
Punitive damages depend on success on the underlying claim
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Ellison v. Fry, 437 S.W.3d 762, 777 (Mo. banc 2014): The Court applied the rule that punitive damages
are available only if the plaintiff prevails on the underlying claim and is entitled to actual damages. Because
Hanshaw’s liability claims failed on summary judgment, punitive damages necessarily failed as well.
3.2 Legal Reasoning
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Missouri’s gatekeeping framework is codified—and demands proof, not assurances.
The Court treated § 490.065.2(1)(c)-(d) as independent, mandatory requirements: it is not enough that
an expert is credentialed or reviewed “sufficient facts or data.” The proponent must show (c) reliable principles and
methods and (d) reliable application to the case.
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“Personal observations” and experience do not substitute for an explained, reviewable methodology.
Hanshaw argued reliability because the expert observed the forklift and accident scene, reviewed video, built models,
and performed “safety engineering analyses.” The Court found this framing blurred the statutory lines: without a
disclosed methodology, the court cannot assess reliability.
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The “analytical gap” problem controlled.
Relying on Gen. Elec. Co. v. Joiner, the Court emphasized that even where an expert has data (e.g.,
accident reports, OSHA data), the opinion is inadmissible if the link between data and conclusion is only the
expert’s ipse dixit. Here, the proponent failed to demonstrate:
- what data the expert actually used and how;
- what test protocols, calculations, standards, or engineering principles were applied;
- how the proposed alternative designs (door/bumper) were validated as safer, feasible, or risk-reducing.
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Absent the methodology and supporting materials, the circuit court could not do Daubert’s job.
The opinion repeatedly returns to a practical gatekeeping constraint: if the proponent does not provide the
methodology and supporting documentation, the circuit court cannot evaluate testability, peer review, standards, or
general acceptance.
The Court found it dispositive that the peer-reviewed papers were not produced and their relevance was not shown,
and that alleged testing was described only at a high level without methodology or results.
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Once the expert is excluded, summary judgment follows if the expert was the only proof of defect/causation.
By invoking L.A.C. ex rel. D.C. v. Ward Parkway Shopping Ctr. Co. and Rule 74.04(e),
the Court treated admissibility as a necessary condition to create a triable factual dispute at summary judgment.
Because Hanshaw relied on the excluded opinions to establish defect/unreasonable danger (and related theories),
summary judgment was “proper.”
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Punitive damages fall with the underlying claim.
Applying Ellison v. Fry, the Court held punitive damages cannot proceed independently when the
underlying liability claim has been resolved against the plaintiff.
3.3 Impact
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Elevated practical burden on plaintiffs in design-defect cases.
Hanshaw underscores that design-defect experts must do more than identify an intuitive “safer” concept.
The proponent must present a reviewable basis: testing, calculations, standards, validation of alternative designs,
and an explained inferential path from data to conclusions.
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Expert exclusion becomes a summary-judgment lever—especially after discovery closes.
By emphasizing timing (with reference to Rhoden v. Mo. Delta Med. Ctr.), the opinion highlights a
litigation reality: reliability defects may be incurable once scheduling deadlines pass, making early, document-backed
methodology disclosure strategically essential.
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Reinforcement of “record hygiene” under Rule 74.04.
Citing Green v. Fotoohighiam, the Court signals that parties must properly place supporting material
into the summary-judgment record; courts will not search the broader file to rescue under-supported expert opinions.
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Clarification that Missouri’s § 490.065 is a true Daubert-style gatekeeping statute.
The opinion aligns Missouri practice closely with federal Rule 702 jurisprudence (Daubert/Joiner), encouraging more
rigorous motion practice focused on methodology rather than credentials or conclusions.
4. Complex Concepts Simplified
- Section 490.065.2(1)(c)-(d): “reliable principles and methods” and “reliable application”
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It is not enough for an expert to be experienced or to have looked at information. The expert must use a dependable
method (e.g., tested engineering analysis, validated modeling, accepted standards) and must show how that method was
applied to the specific facts of the accident and product design.
- Daubert factors
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A set of flexible checks for scientific/technical reliability: can the method be tested, was it peer reviewed, does
it have known error rates/standards, and is it generally accepted. The factors are not a checklist, but they provide
a way to evaluate whether an opinion is grounded in more than intuition.
- Ipse dixit
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Latin for “he himself said it.” In this context, it means an expert’s conclusion cannot be accepted merely because
the expert asserts it. The opinion must be supported by an explained methodology.
- “Analytical gap”
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When an expert has some data (like accident reports) but does not explain the reasoning steps that connect that data
to the conclusion (like “a door would have prevented this injury”), the gap is too large and the testimony can be
excluded.
- Summary judgment and admissible evidence
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At summary judgment, the court considers whether a case has enough admissible proof to justify a trial. If the
plaintiff’s only evidence on a necessary element is inadmissible (such as an excluded expert opinion), the defendant
can win without a trial.
5. Conclusion
Hanshaw v. Crown Equipment Corp. reinforces a stringent, method-focused application of
§ 490.065: expert opinions in technical product cases must be supported by disclosed, evaluable
principles and methods and a clear explanation of their application—credentials, observations, and references to data
are not enough. By coupling that gatekeeping holding with Missouri’s summary judgment doctrine that only admissible
evidence can create a triable issue, the Court confirms that exclusion of the plaintiff’s sole expert commonly
resolves the case as a matter of law. Finally, the decision reiterates that punitive damages cannot survive the failure
of the underlying liability claim.