In Crouch v. Teledyne Continental Motors, Inc., 2011 WL 2600450 (S.D. Ala 2011), the court analyzed whether a mechanical engineer with a Masters Degree in structural analysis was qualified to testify whether a fire occurred in-flight or post-crash. The court looked at his specific qualifications as to the specific opinion the expert intended to offer. 

The court noted that neither the expert's resume nor his testimony at the hearing provided any basis for the expert to opine when the fire occurred. The expert was unable to state the cause or origin of the fire but relied upon soot patterns to indicate that the fire occurred post-crash. The court found that the opinion was not supported by any specialized knowledge, training or experience in identifying when the fire occurred.