U.S. District Court (Hawaii) Excludes Testimony on Business Value From an Attorney Who Has No Valuation Skills

BVLaw
Court Case Digests
October 2, 2024
5411 Grocery Stores
445110 Supermarkets and Other Grocery Retailers (except Convenience Retailers)
estate and gift taxation
expert witness, appraisal, rule 702, stock, reliability, gift, qualifications, motion in limine

Sullivan v. Loden (II)
2024 U.S. Dist. LEXIS 180494
US
Federal Court
Hawaii
United States District Court
Mark Murakami
Micah W.J. Smith

Summary

The U.S. District Court in this case excluded the value of an attorney who was appointed in a related state probate case and testified that the defendant’s valuations were unreliable. The district court determined that the proposed witness was not qualified to testify as to the efficacy of valuations. This case concluded that just because a proposed witness was an “attorney” “respected” as an estate expert did not make him or her qualified under Rule 702 to testify about business valuations when the proposed witness was not qualified in business valuation.

See Also

Sullivan v. Loden (II)

The U.S. District Court in this case excluded the value of an attorney who was appointed in a related state probate case and testified that the defendant’s valuations were unreliable. The district court determined that the proposed witness was not qualified to testify as to the efficacy of valuations. This case concluded that just because a proposed witness was an “attorney” “respected” as an estate expert did not make him or her qualified under Rule 702 to testify about business valuations when the proposed witness was not qualified in business valuation.