O'DOWD v. Linehan

I concur with the result in this case for reasons stated in my concurring opinion in People v. Zimmerman, (1971), 385 Mich 417, decided today. In the Zimmerman case, Billings would have testified in two different areas of expertise. First, as to speed from skid marks, there was an inadequate showing of data that the state of the art is developed to the point that it has a reasonable degree of reliability. Second, as to speed plus impact, there was no showing of the state of the art or the witnesses’ qualifications in the area.

The facts of this case involve accident reconstruction which is an…