St. John's University School of Law
American Bankruptcy Institute Law Review

Squaring Bankruptcy Valuation Practice With Daubert Demands

Stan Bernstein, Susan H. Seabury, Jack F. Williams

The Honorable Stan Bernstein, Susan H. Seabury, and Professor Jack F. Williams provide the issue's fifth article, Squaring Bankruptcy Valuation Practice With Daubert Demands.  This piece studies the issue of how bankruptcy courts manage expert testimony on valuation.  The article addresses the Supreme Court decision in Daubert v. Merrell Dow Pharmaceuticals, Inc., which sets forth new guidelines for federal courts when dealing with expert valuation testimony.  The authors then examine valuation tools utilized by experts in bankruptcy cases and design a system to address the relevance and reliability concerns discussed in Daubert.  Finally, the authors look to recent valuation decisions to illustrate how expert valuation testimony can be squared with Daubert standards.