Goldberg Segalla partner Alex P. Blair authored a column for Illinois Defense Quarterly examining a recent Seventh Circuit decision affirming the exclusion of plaintiffs’ expert testimony and the resulting summary judgment victory for a product manufacturer.

Alex, a partner in the firm’s Chicago office, represents a variety of manufacturers in complex product liability and toxic tort matters and serves as the Product Liability columnist for Illinois Defense Quarterly.

In his column, “Seventh Circuit Upholds Barring of Plaintiff’s Experts Due to Failure to Prove Product Defect and Unreliable Methodology in Uniform Dye Exposure Matter,” Alex analyzes the court’s October 2025 decision in Gilbert v. Lands’ End, Inc., which affirmed the Western District of Wisconsin’s exclusion of plaintiffs’ defect and causation experts under Federal Rule of Evidence 702.

The case arose from lawsuits filed by hundreds of Delta Airlines employees who alleged injuries and property damage resulting from exposure to chemicals and dyes in new uniforms supplied by Lands’ End. While one group of plaintiffs pursued express warranty claims for property damage, another alleged personal injuries ranging from headaches and anxiety to breathing difficulties. The district court consolidated the actions and ultimately granted summary judgment in favor of Lands’ End after excluding plaintiffs’ expert opinions.

Alex explains that the Seventh Circuit devoted much of its opinion to the plaintiffs’ failure to establish evidence of a product defect under Wisconsin law. Although plaintiffs’ textile expert opined that the uniforms used a defective dye process and leached various substances, the expert could not identify whether the alleged chemical transfer constituted a defect or occurred at harmful levels. The court found this evidentiary gap fatal to the plaintiffs’ claims.

The column also explores the Seventh Circuit’s analysis of expert methodology under Rule 702, including its discussion of the December 2023 amendments to the rule. Alex notes the court’s recognition of potential tension between those amendments, which expressly emphasize reliable application of principles and methods, and earlier Seventh Circuit precedent distinguishing methodology from conclusions. While the court declined to resolve that tension directly, it suggested an increased openness to challenging expert conclusions that are insufficiently supported by data.

READ THE FULL ARTICLE HERE

MORE ABOUT GOLDBERG SEGALLA’S Alex P. Blair:

Alex is an experienced defense attorney who represents manufacturers of a variety of products and owners of food, beverage, and refining facilities in complex product liability and toxic tort matters. In addition to defending clients in Illinois, Indiana, and Texas, Alex has handled depositions on behalf of clients in Pennsylvania, New Jersey, and New York and analyzed relevant statutes and case law in defense of lawsuits filed in jurisdictions across the country.

Alex has managed cases as local counsel from initial filing through final disposition and collaborated with national coordinating counsel to formulate strategy and report litigation developments. Before joining Goldberg Segalla, his practice included litigating premises liability, commercial, real estate, employment and labor, construction, professional liability, and insurance coverage disputes.