The Role of the Expert Witness

Reviewed Feb 2017The role of an expert witness is important and vital to the proper functioning of the architectural profession.Occasionally concern is expressed about the quality and veracity of expert evidence presented by some architects and building surveyors who engage in this professional activity. Is it justified?The High Court Rules provide a code of conduct for experts, but it might be timely to reiterate the nature of expert evidence, with particular reference to claims which allege professional negligence on the part of an architect.

  1. You are engaged as an architect expert, NOT as an expert architect. Think about the subtlety of this distinction. ie; you must possess expertise in the subject upon which you give an opinion. Your evidence should be precise, well-reasoned, concise and easily understood by lay persons. [Refer para 5 post]
  2. The expert witness’s over-riding duty is to the court and they must remain impartial at all times. Their reports are addressed to the court.
  3. An ordinary witness can only comment upon facts within his or her knowledge and is prevented from giving an opinion based upon the facts. An expert witness, however, is entitled to give an opinion based upon facts relating to their area of expertise only. He or she can comment upon the significance of the facts being considered and can draw inferences from them.
  4. The purpose of the architect expert’s evidence is to assist the judicial tribunal to understand the nature of architectural matters and service relating to the case being considered. It is intended to assist the lawyers and judge(s) to understand matters which may be outside their particular expertise. (Technical arbitrators may sometimes be chosen for their particular field of expertise) It is not the expert’s role to determine liability; this function is reserved for the judge or tribunal.
  5. In litigation which enquires into the competence of an architect, the opinion being sought is: “what is the standard of conduct expected of a reasonable and competent architect undertaking similar work under similar circumstances at the time of the alleged act or omission?” The test is what a reasonable and competent architect would or would not do, when judged against the standard of the architectural profession generally, and NOT against the conduct or expectations of the expert witness personally.
  6. The evidence needs to establish the basis for any assumption that the architect’s conduct fell short of, was consistent with, or exceeded that expected of a competent architect. This implies that you are aware of the skill and conduct of architects generally at the relevant time. (The court may reject the expert’s opinion as to the reasonable standard expected of a profession, if it considers that a higher standard is warranted in the public interest.)
  7. The architect expert should clearly answer the questions posed by the instructing solicitor/barrister, giving reasons for any opinions held. If there is currently insufficient information to form an opinion, the expert should say so. If a particular question falls outside the expertise of the witness, the expert should advise accordingly.
  8. The architect expert should be aware of and understand the contractual obligations accepted by the architect under investigation. Contractual terms may be expressed, or implied. The opinion given should have considered both alternatives if appropriate.
  9. There may sometimes be a need for a form of architectural advocacy, but this generally occurs in discussion with the instructing barrister during an early stage of investigation, when overall legal strategy is being considered and your instructions are being refined.
  10. Opinions that you may have in this role, should always be conveyed separately to your instructing solicitor and never included within the body of your expert evidence. It is expected that an expert witness should identify the strengths and weaknesses of other expert witnesses and refer this to the instructing solicitor, prior to or during the trial.
  11. Evidence which is perceived by the tribunal to be biased towards advocacy, will be readily identified as such, particularly during cross examination if it gets that far. Your reliability as a creditable expert witness will then be compromised thereafter.
  12. Because of the high cost of litigation, the attendant risk of one or other side losing and then having to contribute in part to the other party’s legal costs, there is often a strong commercial and emotional incentive for the parties to negotiate a settlement before the trial. Anecdotally, 90 - 95% of all such litigation is resolved outside the court forum. Here, with a negotiated or mediated settlement, the outcome is agreed between the parties rather than being imposed upon them by a dispassionate judge who will consider the facts, the expert evidence, legal principles and precedent only.
  13. Evidence which has the clear appearance of advocacy, actually hinders the negotiated settlement process, by elevating the expectations of one party over the other. In such circumstances, considerable energy and time is expended in realigning the expectations of the relevant parties. We see countless examples of this in leaky building claims.
  14. An expert witness should always review his or her opinion when the original evidence changes, or when the opposing expert’s evidence is compelling. Compromise is not necessarily a back-down.
  15. Expert witnesses enjoy immunity from suit if their evidence is given honestly and in good faith. However, in cases of perceived gross incompetence as an expert witness, the expert may be liable to their client for want of skill and care. In a UK judgement, the court referred an architect expert witness to the disciplinary tribunal of the Architects Registration Board. In this particular case, based upon the facts and the evidence presented by other architect expert witnesses, the tribunal found in favour of the respondent. [Michael Wilkey. Architects Registration Board UK. 5 Feb 2003]

The Nature of Expert Evidence

As to the nature and quality of architect expert evidence, I draw your attention to a 2013 judgement which involved the participation of many expert witnesses. The judge’s insight into the quality of their evidence is worthy of note for those who may contemplate undertaking the role of an architect expert witness. [For those wishing for more architectural chronology and construction details, refer to High Court of Justice, Queens Bench Division, Technology and Construction Court in England, Case No HT-11-374].By way of background, these proceedings related to the quality of architectural services provided by AEW in their design, detailing and construction-observation of the Museum of Liverpool, which was undertaken between 2007 and 2011. The museum had a dramatic and interesting design, with sweeping roofs and two separated half-amphitheatres comprising steps and seats at the north and south ends. It attracts hundreds of thousands of visitors each year. The seats, steps and terraces suffered from overall design problems and architectural decisionsThe following extracts from this judgement, which relate to the evidence of witnesses and expert witnesses, are italicised hereafter.

Witnesses

No factual witnesses were called by the Architect, AEW, and no explanation or evidence as to why they adopted this course.The Executive Director of the museum was astute and experienced in her job. Her comments had a ring of absolute truth. She was prepared to make concessions with regard to some of the quantum evidence which underlined the basis of her honesty and integrity.She was subject to polite but firm cross examination, but stood up well to that and I found her immensely believable.The project Quantity Surveyor was found to be a decent and convincing witness.The Contract Administrator had 26 years of management experience on large-scaled construction projects. Initially nervous, he gained confidence. He was a decent and positive witness and broadly a creditable witness.The museum’s Director of Estate Management was a straightforward witness, ready to concede. I found him impressive and believable.

Other witnesses were seen as being:

Down to earth, sensible and honest. A sensible and decent straight forward witness. A reliable witness.The contractor’s Project Quantity Surveyor did not always answer relatively simple questions put to him. Much of his written evidence was not challenged, but I am circumspect about the reliability of his evidence where it differs from contemporaneous documents.

Expert Witnesses

The museum’s Architect expert was an extremely experienced architect and indeed, expert. He produced by far, the best expert report of all the architect experts. He was able to explain himself in a language that non-architects could understand.In contrast, the architect expert called by the Architect, AEW, was wholly unimpressive, possibly partly because he had never given expert evidence before. He had given little or no coherent thought to the issues of the case, and had not been asked to consider what could reasonably have been expected of an architect in AEW’s position. He was wholly unconvincing about all aspects of liability. He accepted that he was “seeking to defend the indefensible for the benefit of AEW.” He was faltering in his evidence and often did not seem to understand the questions. I can place no weight on any of his evidence.The defending party’s experts moved a not insignificant way towards the museum’s architect expert’s view – confirming that he was the more reliable expert.The museum’s engineer expert was the most experienced engineer giving evidence. He was straight forward in his evidence, authoritative and pragmatic.The architect’s engineer expert was often argumentative, if not combative when cross-examined. I would not describe him as partisan, but his behaviour in the witness box inevitably coloured my views about the reliability in this case.The contractor’s engineer expert was the least experienced of the three. He was decent and straight forward, but his approach to the particularities involved with the design was somewhat academic.

Competing Opinions

This case involved often competing expert evidence, which was contested under rigorous cross-examination and appropriate weight then given to the credibility of each witness.This weighting is rarely given in situations where the competing expert evidence is considered within a mediated settlement forum. In such situations, the relative credibility of competing expert evidence cannot be properly assessed within the time set aside for the mediation. It is in these instances (90-95% of disputes) that greater reliance must be placed upon the true, competent and unbiased quality of expert evidence. Unless the competing expectations of both parties are properly orientated, much precious time will be wasted in attempting a realistic alignment of their respective expectations during the early stages of the mediation process and an unfair outcome may ultimately result.An expert witness’s opinion should be always consistent, irrespective of who pays the fee.Graham StrezClaims Director, NZACS

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