Must an expert witness be a human?

Yes, says the Delaware Chancery in the Dole shareholder litigation, according to the BVWire. The precise issue was whether Dole could designate its financial advisory firm as its valuation expert, as opposed to the individuals  who wrote the expert report. Even though the Delaware Code includes provisions that “appropriately personif[y]” corporations, companies, and firms in certain commercial and economic contexts, “the Rules of Evidence make clear that a witness must be a biological person,” the court said [In re Dole Food Co., Inc. Stockholder Litigation, 2015 Del. Ch. LEXIS 47 (Feb. 27, 2015)].