The Eleventh Circuit held that it was proper for the district court to consider an expert’s credentials at evaluating whether his methodology was reliable. In Tampa Bay Water v. HDR Engineering, Inc., 731 F.3d 1171 the trial court, after a Daubert hearing permitted an expert’s opinion. One of the issues on appeal was that the expert’s methodology was faulty. In response to this the Court of Appeals said:
“TBW also asserts that HDR’s sole argument for reliability was an invocation of Bromwell’s impressive credentials. Yet Bromwell’s explanation of his method was a logical one, not a mere assertion of his credentials. Moreover, it was not improper for the district court to consider Bromwell’s credentials in evaluating whether his methodology was reliable. Although an expert’s qualifications go primarily to the first prong of Daubert’s inquiry, “an expert’s overwhelming qualifications may bear on the reliability of his proffered testimony” even if “they are by no means a guarantor of reliability.” Id. at 1341. In this case, Bromwell received both his bachelor’s degree, in Chemical Engineering, and his doctorate, in Civil Engineering, from MIT. He spent his academic career authoring or co-authoring cozens of articles in the area of soil science, and his nonacademic career was devoted to the design, analysis, and evaluation of earthen embankments. In fact, Bromwell had designed thirty to forty earthen embankments, most of which were reservoirs or similar projects. These qualifications bolstered HDR’s showing of reliability, and the district court committed no manifest error by allowing the jury to hear Bromwell’s testimony.”