Plaintiff Geoffrey Long brought this action against Defendants Power Technique North America LLC (“Power Technique”) and United Rentals (North America, Inc.) (“United Rentals”), asserting claims for strict products liability, negligent products liability, and breach of warranty. Long alleged that he sustained life-altering injuries, including significant injuries to his cervical spine, when an access door of a portable air compressor fell on him while he was inspecting the machine in the course of his employment as a General Foreman at a job site in New Jersey.
Defendants filed motions to exclude the testimony of Craig D. Clauser pursuant to Federal Rule of Evidence 702.
Safety Engineering Expert Witness
Craig David Clauser is an engineer with over fifty years of experience in industrial safety, machinery safeguarding, failure analysis of mechanical and structural devices, and accident investigation. He has particular expertise in metallurgical engineering and materials science, and safety engineering.
Discussion by the Court
Clauser concluded that the incident and Long’s injury occurred because the subject air compressor was a “defectively designed product.” Specifically, he opined that “the design did not address the hazard of a gas spring failure allowing a door to drop and strike a user.”
i. Insufficient Facts or Data
Defendants first argued that Clauser’s testimony should be excluded insofar as it rests on insufficient facts or data, specifically an “assumption” that the gas strut failed. Defendants contended that Clauser’s testimony should be excluded in its entirety because it depends on Long’s eyewitness testimony that the gas strut failed. Long correctly responded that such reliance is permissible.
Clauser was unable to inspect the gas strut at issue, which Defendants’ own expert opined had likely been discarded, and instead inspected the machine with new gas struts installed. He paired that inspection with reliance on Long’s testimony that the door fell on him after the gas strut had failed. The Court found that reliance on this evidence is sufficient. Any challenges to the credibility of Long’s testimony that the gas strut failed are better left with the jury, not the judge.
Defendants also argued that Long’s eyewitness testimony is an insufficient fact to support Clauser’s conclusions because Clauser, in relying on that fact, “performed no analysis into why the gas struts did not need to be replaced until February 2025 by United Rentals.”
Long responded, and the Court agreed, that Defendants misconstrued Clauser’s testimony. At his deposition, Clauser stated: “I don’t know that they weren’t replaced, and I did not really put any analysis into that.” That is not the same as Clauser admitting that “he performed no analysis into why the gas struts were not replaced until February 2025.”
Finally, Defendants argued that Long’s eyewitness testimony is insufficient because Clauser did not rule out alternative explanations. According to the Court, where alternative explanations conflict with eyewitness testimony, an expert may rely on the eyewitness account.
ii. Reliable Principles and Methods
Defendants challenged Clauser’s alternative-design opinions on the ground that he proposed those alternatives without “testing, data analysis, or calculations,” and instead merely “showed a picture of the two alternatives without any diagrams.”
But the absence of testing, standing alone, does not render an alternative-design opinion unreliable per se. Here, Clauser’s opinion concerning the formation and necessity of alternative designs rests on his substantial experience, his personal inspection of the compressor, his review of the record, and his application of the Order of Precedence or Safety Hierarchy.
Accordingly, the Court held that any lack of testing goes to the weight of Clauser’s opinion, not its admissibility.
Defendants separately argued that Clauser’s methodology in providing alternative designs is insufficient because he did not independently test the lifespan of a gas strut. But Clauser’s report made it clear that he relied on the testimony of Mark MacInnis, Power Technique’s former Vice President of Engineering for its Portable Power and Flow Division, regarding the lifespan of the struts. MacInnis testified that it would be unlikely “if there was anyone in the globe who knew more about this product than me.” Clauser’s reliance on that testimony was considered permissible.
Finally, Defendants faulted Clauser because they averred that no manufacturer had implemented his proposed alternative design. But Defendants did not meaningfully explain how that fact rendered Clauser’s methodology unreliable and cited no authority imposing a categorical requirement that an expert demonstrate industry use of the precise alternative design he proposed.
iii. Warnings or Instructions Testimony
Defendants also challenged Clauser’s warning opinion that Power Technique should have warned that “air springs were susceptible to unexpected failure” and that users should not rely on them as the sole means of support. Defendants contended that this opinion is improper because Clauser did not know the failure rate of the gas struts at issue, “did not know of any really sudden failure of a gas strut,” and again asserted that Clauser does not know that a gas strut failed in the subject accident.
These arguments do not warrant exclusion of his testimony. As discussed above, Clauser relied on Long’s eyewitness testimony in concluding that a gas strut failed, and such reliance is permissible.
Defendants next argued that Clauser’s opinion that Power Technique “could have provided instruction to the owner and maintainer of the compressor that the air springs, which Mr. MacInnis stated are inexpensive, should be replaced at a frequency that prevents end of life failures in service” is based on unsupported conjecture and speculation. The record does not support that characterization. Clauser acknowledged that the lifespan of a gas strut depends on the strut’s usage and the environment in which it is used. But that does not make replacement-frequency information unknowable or speculative.
Defendants further faulted Clauser for not identifying similar replacement schedules for gas struts across other industries and for not relying on specific industry standards governing regular replacement of gas struts. But the absence of industry standards or comparable replacement schedules did not, by itself, require exclusion.
Held
The Court denied Defendants’ motions to exclude the testimony of Craig D. Clauser.
Key Takeaway
Clauser relied on his personal inspection of the compressor, his review of the record, and his decades of experience in engineering, safety engineering, machinery safeguarding, failure analysis, and accident investigation. Defendants’ criticisms of the factual basis for his warning opinion may go to its weight, but they do not render the opinion inadmissible.
Case Details:
| Case Caption: | Geoffrey L. Long v. United Rentals N. Am., Inc. |
| Docket Number: | 2:25cv4432 |
| Court Name: | United States District Court, Pennsylvania Eastern |
| Order Date: | June 24, 2026 |
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