Case: Williams v. Leesburg Regional Medical Center Inc.
Decided: February 06, 2026

The Fifth District Court of Appeal’s recent decision in Williams v. Leesburg Regional Medical Center Inc. represents a significant reaffirmation of the trial court’s role as a gatekeeper regarding the admissibility of expert testimony under the Daubert standard.

In this particular case, the Plaintiff brought medical malpractice claims against a medical facility following the tragic death of an infant from pertussis (a highly contagious respiratory tract infection) and rhino enterovirus. The litigation focused on whether a delay in administering antibiotics at the initial facility probably caused the child’s death. The trial court excluded several of the Plaintiff’s expert witnesses, finding their opinions on causation to be speculative and noting they “did not meet the reliability threshold for admissibility because they did not rely on testing, peer review, potential error rate, or general acceptance.” Williams v. Leesburg Reg. Med. Ctr. Inc., 2026 Fla. App. Lexis 870, Pg 4. (Fla. 5th DCA, 2026). Summary judgment was granted.

On appeal, the Court was asked to consider whether the trial court erred in excluding these experts. Upon a proper challenge to expert testimony, its proponent bears the burden of establishing admissibility. The Court examined each expert’s testimony and found that none could produce a scientifically reliable basis for why earlier intervention would have prevented the infant’s death. Instead, the experts relied on their own experience and assumptions to reach their conclusions, failing to provide a reliable scientific nexus between the hospital’s inaction and the infant’s death.

Ultimately, the Court reiterated that under the Daubert standard, it is not enough for an expert’s theory to be "plausible". Instead, the expert's opinion must be grounded in a methodology that is testable and supported by reliable data. The Court identified a significant "analytical gap" between the data presented and the opinions proffered by the experts, who relied on the broad premise that "earlier treatment is better". Because the experts could not provide a scientifically reliable basis to prove that a specific 12 to 24 hour delay more likely than not caused the untimely death, their testimony was deemed inadmissible. Williams v. Leesburg Reg. Med. Ctr. Inc., 2026 Fla. App. Lexis 870, Pg 17. (Fla. 5th DCA, 2026).

The Court found that while an expert does not have to establish causation conclusively to be admissible, a reasonable judge could conclude that the testimony proffered was not sufficiently reliable or helpful to a jury. The Court affirmed the trial court’s ruling, finding no abuse of discretion in the exclusion of the experts.

This decision maintains a clear benchmark for expert testimony, requiring that opinions specifically rely upon verifiable data rather than an expert’s personal experience or assumptions alone. Should an expert fail to provide specific testimony and data to support their opinions establishing causation, those opinions are properly excluded.

"This ruling reinforces the essential role of the trial court as a gatekeeper," said Orlando Managing Partner Robin Khanal. "It is no longer enough for an expert to be qualified; their specific testimony must be anchored in rigorous, verifiable data to ensure that only the most reliable evidence reaches the jury."

Update from:

• Joshua Fittler, Orlando Associate
• Robin Khanal, Orlando Managing Partner

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