Section 13.34 Expert Testimony on the Value of Services

• Library: Sources of Proof (2014 Ed.)

B. (§13.34) Expert Testimony on the Value of Services

A properly qualified expert may testify as to the value of services. Examples have occurred in a variety of cases, including testimony regarding the value of:

· services in selling and promoting shoes, Vosevich v. Doro, Ltd., 536 S.W.2d 752 (Mo. App. E.D. 1976);

· services of an attorney, Wurtz v. Daniel Hamm Drayage Co., 530 S.W.2d 752 (Mo. App. E.D. 1975);

· nursing services, Ashley v. Williams, 281 S.W.2d 875 (Mo. 1955);

· farm services, Ridinger v. Harbert, 409 S.W.2d 764 (Mo. App. W.D. 1966); and

· services of an architect, Stokes v. Enmark Collaborative, 634 S.W.2d 571 (Mo. App. E.D. 1982).

Expert testimony may be required to determine the reasonable cost of work and whether the work was performed in a workmanlike manner. Williams Carver Co. v. Poos Bros., Inc., 778 S.W.2d 684, 687 (Mo. App. W.D. 1989) (an action for breach of warranty in the installation of a refrigeration system).

Expert testimony may be offered on the...