In the “Daubert trilogy,” Rule 702 spawned three children, all special in their own way. The firstborn, Daubert v. Merrell Dow Pharms., Inc., 509 U.S. 579 (1993), naturally receives most of the attention, being the pioneer. The middle child, General Elec. Co. v. Joiner, 522 U.S. 136 (1997), tends to be comparatively underappreciated in the shadow of its predecessor. Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (1999), the youngest, generally receives the least attention.
Daubert’s broad pronouncements about gatekeeping principles dominate the Rule 702 landscape. No one calls a motion to exclude a “Joiner motion”; no one participates in a “Kumho hearing.” But in the broad wake of Daubert, Joiner played a particularly important and multifaceted role in shaping the ongoing development of Rule 702 jurisprudence. Its influence is worth revisiting.