Requirement of Expert Testimony for Standard of Care in Specialized Equipment Maintenance

Introduction

In Seymour v. State, 2025 MT 88, the Supreme Court of Montana addressed whether a plaintiff in a negligence-premises liability action must present expert evidence to establish the standard of care for maintaining specialized exercise equipment. Derik L. Seymour sued the State of Montana and the University of Montana-Western after a cable crossover machine snapped and severely injured him. The parties litigated discovery deadlines, expert disclosures, and ultimately summary judgment based on Seymour’s failure to offer admissible expert proof of the State’s duty and breach. This commentary examines the factual and procedural background, key issues, court findings, and the broader legal significance of the decision.

Summary of the Judgment

On April 29, 2025, the Montana Supreme Court unanimously affirmed summary judgment for the State. The District Court had held that Seymour failed to present admissible evidence of the State’s standard of care in maintaining the exercise machine—a critical element of his negligence claim—and that the matter was beyond the ordinary knowledge of lay jurors. Seymour’s disclosed expert, Mr. Larry Smiltneek, produced an investigatory report on cable failure but did not offer reliable opinions on the State’s maintenance duties or practices. Seymour also failed to bring Smiltneek to deposition or confirm his testimony for trial. The Supreme Court agreed that expert testimony was necessary and absent, and further found Seymour’s pro se procedural delays did not justify relief from these basic requirements.

Analysis

Precedents Cited

• M. R. Civ. P. 56 (Summary judgment standards): Requires that no genuine issue of material fact exists and the movant is entitled to judgment as a matter of law.
• Buckley v. Western Montana Community Health Center, 2021 MT 82: Reiterated the de novo review standard for summary judgment motions.
• Hagen v. Dow Chemical Co., 261 Mont. 487 (1993): Noted that negligence issues ordinarily go to a jury unless an essential element lacks any supporting evidence.
• Kostelecky v. Peas in a Pod LLC, 2022 MT 195: Confirmed that failure to present evidence on any negligence element supports summary judgment.
• Dubiel v. Montana Department of Transportation, 2012 MT 35: Held that expert testimony is required when the relevant standard of care falls outside common experience.
• Horn v. St. Peter’s Hospital, 2017 MT 298: Clarified that manufacturer recommendations alone do not substitute for expert evidence of professional standards.
• Greenup v. Russell, 2000 MT 154: Confirmed that pro se litigants must comply with procedural rules and cannot prejudice opposing parties by disregard of deadlines.

Legal Reasoning

1. Negligence Elements: Duty, breach, causation, and damages. Seymour needed expert evidence to define the State’s duty in inspecting and maintaining complex gym equipment.
2. Beyond Common Knowledge: The Court determined that assessing cable fatigue, internal wear, stress patterns, and appropriate inspection schedules is technical and beyond the average juror’s experience.
3. Expert Disclosure and Deposition: Seymour’s only expert report speculated on cable failure causes but did not articulate accepted maintenance protocols or industry standards. His failure to produce Mr. Smiltneek for deposition or secure reliable testimony for trial was fatal.
4. Procedural Posture: Despite multiple extensions and warnings, Seymour—proceeding pro se—did not cure his discovery deficiencies or present admissible expert affidavits. The Court declined to consider new arguments on appeal regarding lay juror competence because they were not raised below.

Impact

Seymour v. State reinforces several important principles:

• Expert testimony is indispensable when a negligence claim turns on specialized technical standards or professional practices.
• Manufacturer guidelines may inform jurors but cannot replace a qualified expert’s opinion on the applicable standard of care.
• Pro se litigants receive procedural latitude but must adhere to discovery rules and expert witness requirements to avoid prejudice to the opposing party.
• Future plaintiffs seeking to challenge maintenance of complex machinery—whether in gyms, construction, or medical settings—must secure and disclose competent expert testimony that expressly addresses the standard of care and breach.

Complex Concepts Simplified

• Summary Judgment: A court decision without a full trial when one side shows no real dispute over facts essential to win the case.
• Standard of Care: The degree of caution and skill expected of a reasonable person or entity under similar circumstances, often proved by expert witnesses in technical fields.
• Expert Witness Disclosure: A formal statement listing experts who will testify, their opinions, and underlying reports or data.
• Pro Se Litigant: A person who represents themselves in court without an attorney.
• Negligence-Premises Liability: A legal theory holding property owners responsible for injuries due to unsafe conditions on their premises.

Conclusion

Seymour v. State establishes that, in Montana negligence law, plaintiffs must present admissible expert evidence to define and prove breaches of specialized maintenance duties. Lay jurors cannot be expected to evaluate technical safety protocols without expert guidance. The decision also underscores the necessity of compliance with procedural rules—even for pro se parties—and clarifies that summary judgment is appropriate when an essential element of negligence cannot be supported by evidence. This ruling will guide future cases involving equipment safety, professional standards, and the boundaries of lay versus expert testimony.