fair scope rule (Pennsylvania) · Go Syfert
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fair scope rule in Pennsylvania

19 Pennsylvania opinions name it 3 courts 1998–2026 7 in the last five years

The cases below were cited by Pennsylvania courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (9)

CaseFollowedCited
Woodard v. Chatterjeegreen
pasuperct · 2003 · cited in 6 Pennsylvania opinions naming this issue, 2016–2025
2 sentences

2025See Woodard v. Chatterjee, 827 A.2d 433, 445 (Pa.Super. 2003) (citing comment to Rule 4003.5(c) for proposition that the rule is intended “to prevent incomplete or ‘fudging’ of reports which would fail to reveal fully the facts and opinions of the expert or his grounds therefor”); see also Jones v. Constantino, [ 631 A.2d 1289, 1294 (Pa.Super.] 1993) (noting the fair scope rule “disfavors unfair and prejudicial surprise”).

2021See Woodard v. Chatterjee, 827 A.2d 433, 445 (Pa.Super. 2003) (citing comment to Rule 4003.5(c) for proposition that the rule is intended “to prevent incomplete or ‘fudging’ of reports which would fail to reveal fully the facts and opinions of the expert or his grounds therefor”); see also Jones v. Constantino, 429 Pa.Super. 73 , 631 A.2d 1289, 1294 (1993) (noting the fair scope rule “disfavors unfair and prejudicial surprise”).

56
Jones v. Constantinogreen
pasuperct · 1993 · cited in 5 Pennsylvania opinions naming this issue, 1998–2025
2 sentences

2025See Woodard v. Chatterjee, 827 A.2d 433, 445 (Pa.Super. 2003) (citing comment to Rule 4003.5(c) for proposition that the rule is intended “to prevent incomplete or ‘fudging’ of reports which would fail to reveal fully the facts and opinions of the expert or his grounds therefor”); see also Jones v. Constantino, [ 631 A.2d 1289, 1294 (Pa.Super.] 1993) (noting the fair scope rule “disfavors unfair and prejudicial surprise”).

2021See Woodard v. Chatterjee, 827 A.2d 433, 445 (Pa.Super. 2003) (citing comment to Rule 4003.5(c) for proposition that the rule is intended “to prevent incomplete or ‘fudging’ of reports which would fail to reveal fully the facts and opinions of the expert or his grounds therefor”); see also Jones v. Constantino, 429 Pa.Super. 73 , 631 A.2d 1289, 1294 (1993) (noting the fair scope rule “disfavors unfair and prejudicial surprise”).

55
Whitaker v. Frankford Hospitalgreen
pasuperct · 2009 · cited in 3 Pennsylvania opinions naming this issue, 2016–2023
2 sentences

2023Therefore, the opposing party must be prejudiced as a result of the testimony going beyond the fair scope of the expert’s report before admission of the testimony is considered reversible error. -15- J-A05037-23 Whitaker, 984 A.2d at 522 (citation omitted).

2021“In applying the fair scope rule, we focus on the word ‘fair.’” Whitaker, 984 A.2d at 522 (quoting Coffey, 764 A.2d at 620-21 ).

13
Coffey v. Minwax Co., Inc.green
pasuperct · 2000 · cited in 2 Pennsylvania opinions naming this issue, 2013–2021
2 sentences

2021“In applying the fair scope rule, we focus on the word ‘fair.’” Whitaker, 984 A.2d at 522 (quoting Coffey, 764 A.2d at 620-21 ).

2021“Departure from the expert’s report becomes a concern if the trial testimony ‘would prevent the adversary from preparing a meaningful response, or which would mislead the adversary as to the nature of the response.’” Id. (quoting Coffey, 764 A.2d at 621 ).

12
Walsh v. Kubiakgreen
pasuperct · 1995 · cited in 2 Pennsylvania opinions naming this issue, 2003–2020
2 sentences

2020“The admission of expert testimony is a matter within the sound discretion of the trial court, whose rulings thereon will not be disturbed absent a manifest abuse of discretion.” Woodard v. Chatterjee, 827 A.2d 433, 440 (Pa.Super. 2003) (quoting Walsh v. Kubiak, 661 A.2d 416, 419 (Pa.Super. 1995) (en banc)).

2003The fair scope rule, addressed specifically in Pa. R.C.P. 4003.5(c), “provides that an expert witness may not testify on direct examination concerning matters which are either inconsistent with or go beyond the fair scope of matters testified to in discovery proceedings or included in a separate report.” Walsh, 661 A.2d at 420 .

12
Christiansen v. Silfiesgreen
pasuperct · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Christiansen v. Silfies, 667 A.2d 396, 402 (Pa. Super. 1995) (“The fair scope inquiry involves a determination of whether the expert report provides sufficient notice of the expert’s theory to enable the opposing party to prepare a rebuttal witness”) (internal quotation marks and citation omitted). - 14 - J-A20042-25 error alleged [to be] attributable, not to the [trial] court, but to the party seeking relief.” Claudio, 831 A.2d at 141 .

11
Claudio v. Dean MacHine Co.green
pa · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Christiansen v. Silfies, 667 A.2d 396, 402 (Pa. Super. 1995) (“The fair scope inquiry involves a determination of whether the expert report provides sufficient notice of the expert’s theory to enable the opposing party to prepare a rebuttal witness”) (internal quotation marks and citation omitted). - 14 - J-A20042-25 error alleged [to be] attributable, not to the [trial] court, but to the party seeking relief.” Claudio, 831 A.2d at 141 .

11
Expressway 95 Business Center, LP v. Bucks County Board of Assessmentgreen
pacommwct · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
1 sentence

2014See Expressway v. Bucks County Bd. of Assess., 921 A.2d 70, 78-79 (Pa. Commw. 2007).

11
Dible v. Vagleygreen
pasuperct · 1992 · cited in 1 Pennsylvania opinions naming this issue, 1998–1998
2 sentences

1998In applying the fair scope rule, we focus on the word “fair.” Jones v. Constantino, 429 Pa.Super. 73 , 631 A.2d 1289, 1294-95 (1993) (quoting Dible v. Vagley, 417 Pa.Super. 302 , 612 A.2d 493, 499 (1992)).

1998In applying the fair scope rule, we focus on the word “fair.” Jones v. Constantino, 429 Pa.Super. 73 , 631 A.2d 1289, 1294-95 (1993) (quoting Dible v. Vagley, 417 Pa.Super. 302 , 612 A.2d 493, 499 (1992)).

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Pennsylvania. Read the followed side critically anyway.

Also cited on this issue (1)

CaseCitedYears
Wilkes-Barre Iron & Wire Works, Inc. v. Pargas of Wilkes-Barre, Inc. green
pa · 1985
2 sentences

2023In Wilkes– Barre Iron & Wire Works, Inc. v. Pargas of Wilkes–Barre, Inc., 348 Pa.Super. 285 , 502 A.2d 210 (1985), this Court explained that: [I]t is impossible to formulate a hard and fast rule for determining when a particular expert's testimony exceeds the fair scope of his or her pretrial report.

2023In Wilkes– Barre Iron & Wire Works, Inc. v. Pargas of Wilkes–Barre, Inc., 348 Pa.Super. 285 , 502 A.2d 210 (1985), this Court explained that: [I]t is impossible to formulate a hard and fast rule for determining when a particular expert's testimony exceeds the fair scope of his or her pretrial report.

52019–2023

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