Credentialing Expert Witnesses In Unlicensed Professions

Qualifying an expert witness can be a bit slippery for trial courts in matters without clearly defined expert witness requirements. In this premises-liability case, the Mississippi Supreme Court reversed a jury verdict for the plaintiff solely because the trial court should never have allowed the plaintiff's "premises safety" expert, Kenneth Goodrum, to testify. The underlying facts were straightforward: Glenda Mayze slipped and injured her knee on a collapsed, water-covered sidewalk at her apartment complex after management allegedly ignored prior complaints about a disconnected downspout and sinking pavement. The jury found for Mayze, but the sole issue the Supreme Court addressed on appeal was whether Goodrum should have been qualified as an expert at all.

The qualification gap

Mississippi Rule of Evidence 702, like its federal counterpart, requires a two-part showing: the witness must be qualified by "knowledge, skill, experience, training, or education," and the testimony must rest on reliable methodology that will actually assist the jury. The trouble for Goodrum was that "premises safety" isn't a licensed profession, a board-certified specialty, or a field with a defined credentialing path the way medicine, engineering, or architecture are. That ambiguity is exactly what let him get this far in the trial court — and exactly what the Supreme Court used to unwind it.

Goodrum was a high school graduate with no college, trade school, or formal on-the-job training in the field. His background was in the Army and as a Jackson police officer, where he'd picked up some building-code enforcement exposure. His "credentials" consisted of membership in a few trade organizations and online certificates from an eight-hour webinar — one of which covered a tool (a tribometer, used to measure slip resistance) that he admittedly never used in this case. He wasn't a civil, structural, or geotechnical engineer; not a licensed contractor; not a building inspector. His only "workplace experience" in the field came through his own one-man LLC.

The trial court nonetheless qualified him, and the Mississippi Court of Appeals had already found Goodrum unqualified in a nearly identical prior case (the *Womack* litigation) — twice — yet the trial judge here still let him testify, then denied a post-trial motion citing *Womack* with no explanation.

Why the Supreme Court rejected him

The Court's reasoning operated on two independent tracks, both relevant to any expert working in a less-defined field:

1. Credentials and experience, not job title. The Court reiterated that the "scope of the witness's knowledge" controls — not whatever title the witness claims. Simply branding yourself an expert in a field (here, "premises safety") doesn't substitute for demonstrating you actually know "a great deal" about the specific subject matter — in this case, walking-surface hazards and lighting adequacy. The Court noted Goodrum offered none of the "impressive lists of honors, education, and experience" that typically justify the extra weight juries give experts.
2. Methodology, not just a checklist. Separately — and this is the part likely to resonate most with gray-area experts — the Court found that even if Goodrum had been qualified, his *methods* failed Rule 702 independently. He reviewed documents, interviewed a few tenants, walked the property, and measured the depression with a level and tape measure — tools "in many households." He never used a tribometer to test slip resistance, never measured lighting levels, and never applied any methodology requiring specialized, non-lay knowledge. The Court's conclusion was blunt: "Any lay person can read the materials he read and replicate the activities he conducted." That is a methodology problem distinct from the credentialing problem, and it's the kind of criticism that can sink even a well-credentialed witness who nonetheless phones in a formulaic site visit.

This case matters beyond premises safety

The opinion is a useful illustration of how courts scrutinize experts in fields without a clean licensing or board-certification pathway. Where a physician's board certification or an engineer's PE license does much of the qualifying work automatically, witnesses in less standardized fields have to affirmatively build the record: real specialized training (not a webinar), substantive field experience beyond self-employment, and a methodology that uses actual measurement tools and technical standards rather than observations any layperson could make. The Court also flagged that law-enforcement background alone doesn't transfer into civil premises-safety expertise, given the "great trust" juries place in police testimony and the resulting risk of prejudice if that trust is borrowed for an unrelated purpose.

See Park Wind Apartments, LLC v. Mayze (Miss. Oct. 15, 2026)