Supreme Court of New Jersey

Wayne Davis and Irene Laverne Davis

September 15, 2014219 N.J. 395

Summary

The Court held that plaintiffs were required to present expert testimony to establish the standard of care applicable to private fire-sprinkler inspectors because the inspection process and governing regulatory scheme were beyond the ken of an average juror. Plaintiffs' expert offered only a personal, unsupported view that inspectors had to identify and report design flaws, making his testimony an inadmissible net opinion. Because plaintiffs lacked admissible evidence establishing the standard of care and breach, the Court reversed the Appellate Division and reinstated summary judgment for defendants.