Plaintiffs Robert and Jill Motto brought this action to recover for property damage to their home arising from a fire allegedly caused by a defective candle manufactured and sold by Defendants Newell Brands and The Yankee Candle Company.
During the litigation, Plaintiffs retained two experts, Roger Spadt and Dr. John Golder, to investigate the origin and cause of the fire. These experts concluded that the candle was the cause of the fire. Defendants disagreed and have moved to preclude both experts’ testimony, arguing that their opinions do not satisfy the minimum reliability requirements set forth in Federal Rule of Evidence 702.
Fire Investigation Expert Witnesses
Roger A. Spadt has over forty years of public and private experience investigating fires. He was a Fire Chief of a Lehigh Township fire company in 1990. Since then he has worked as Assistant to the State Police Fire Marshal, was a Fire Marshal himself in Lehigh Township, and has been a private fire investigator since 2015.
John J. Golder is a former ATF officer and current forensic fire investigator with a Ph.D. in forensic sciences and over a decade of experience investigating product defects, including candles.
Discussion by the Court
A. Roger Spadt
Based on his investigation, Spadt concluded that the fire was caused by the candle, which he deemed “the only competent ignition source within the area of the fire’s origin.”
Defendants argued that Spadt’s testimony is not reliable because he failed to follow industry guidelines for methodology in fire investigations. Specifically, Defendants argued that he failed to properly analyze the origin of the fire according to the scientific standards set forth in NFPA 921.
1. Industry Guidelines for Fire Investigations
The National Fire Protection Association published an industry guide for investigations into the origin and cause of fires, “NFPA 921.” NFPA 921 sets forth the scientific methods the Association recommends investigators use to determine the cause of a fire. This scientific method generally requires an investigator to “define the problem, collect data, analyze data, develop hypotheses, test the hypotheses, and select a final hypothesis.”
The parties disagreed about the degree to which an investigator must follow every provision of NFPA 921.
Defendants characterize NFPA 921 as “the universally accepted peer-reviewed comprehensive guide to procedures and techniques for fire investigations in the United States.” Plaintiffs have the better argument. The plain text of NFPA 921 makes clear that it is not an exacting set of rules. Section 1.3 states that “deviations from these procedures . . . are not necessarily wrong or inferior.” It explains that “every fire and explosion incident is in some way unique and different from any other,” therefore the guidelines are “not designed to encompass all of the necessary components of a complete investigation or analysis of any one case.”
2. Application of Industry Guidelines by Spadt
It is clear from Spadt’s report that he employed a scientific method that generally comports with the approach outlined in NFPA 921. Spadt collected data by examining the fire scene, taking photographs of the damage, creating a field diagram, and conducting witness interviews.
Spadt also considered alternative causes of the fire, including by examining the home’s branch circuit electric conductors and a ceiling fan as potential induction sources, but ruled out these options because they were inconsistent with the physical evidence and witness interviews.
Finally, even if Spadt’s processes did not adhere to NFPA 921 standards, they independently satisfy Rule 702 and Daubert. Spadt applied the “methods and procedures of science” (in this case, electrical engineering and fire science) to the physical evidence and witness interviews he reviewed in this case, so his opinion rests on “good grounds.”
At bottom, the various issues Defendants raised with Spadt’s testimony are probative of the weight his testimony should be afforded, not the reliability of his methodology. Accordingly, the Court denied Defendants’ motion to preclude Spadt’s testimony.
B. John J. Golder
To begin with, Golder reviewed photographs of the fire scene and witness interviews and conducted a burn test on the same type of Yankee candle. He also determined that the fire was caused by the candle, “which had been burning for an extended period, causing the candle to reach flashover conditions due to the inability of the metal container allowing the heat to dissipate.”
Defendants argued that Golder’s testimony is unreliable because it is not based on sufficient facts or data, not the product of reliable principles and methods, and his conclusions are based solely on unfounded speculation.
1. Insufficient Facts/Data
Defendants argued that Golder’s opinion that the candle reached flashover conditions that resulted in an explosion igniting the materials on the dining room table was reached “without evidence.”
However, Golder based his report on a variety of evidence. He examined the candle’s remains, reviewed photographs and x-rays of the damage to the house, reviewed deposition testimony of witnesses in this case, and conducted a burn test on an identical Yankee candle. Golder also consulted candle safety standards and peer-reviewed literature and employed his knowledge of forensic science, fire dynamics, chemistry, physics, and origin and cause investigations. All of these inputs constitute “good grounds” for Golder’s opinion.
2. Unreliable Methods & Application of Methods
Next, Defendants argued that Golder’s opinion is not based on any scientific method but on mere speculation and his own ipse dixit.
However, Golder relied on his expertise in fire dynamics, fire science, physics, and chemistry, and used that background to examine the candle’s remains, review photographs, x-rays, and deposition testimony, and conduct a burn test of an exemplar Yankee candle. He also consulted relevant literature on fire causation from candles.
In the conclusions section of his report, Golder articulated how his scientific analysis informed his opinion. For instance, he explained that when a glass container is placed into a metal container, it is harder for radiant heat to dissipate away from the glass, meaning the container acts as a heat sink to re-radiate energy back into the glass and cause a flashover. A flashover can cause the flame height to increase, which can break the glass and cause the fire to spread to nearby surfaces. These explanations bridge the gap between Golder’s conclusions and his data and methods.
3. Defendants’ Remaining Arguments
Defendants raised several additional issues with Golder’s report. Namely, that (1) he failed to consider alternative causes of the fire; (2) the burn test he conducted on an exemplar candle and metal holder was not adequately explained and/or sufficiently similar to the circumstances of the fire; and (3) Golder failed to consider the role that Plaintiffs played in causing the fire.
Since these arguments are more probative of the weight to be afforded to Golder’s testimony than the reliability of his methods or conclusions, the Court held that Golder’s conclusions met the minimum reliability requirements of Rule 702.
Held
The Court denied the Defendants’ motion to preclude the testimony of Plaintiffs’ experts Roger Spadt and Dr. John Golder.
Key Takeaway
Courts considering Daubert motions in fire damage cases have found that similar investigatory processes satisfied NFPA 921. Thus, Defendants are wrong that any minor deviation from the guidelines renders Spadt’s investigation unreliable.
Case Details:
| Case Caption: | Motto V. Newell Brands Inc. |
| Docket Number: | 2:24cv1338 |
| Court Name: | United States District Court, Pennsylvania Eastern |
| Order Date: | February 05, 2026 |
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