--- title: "Real Estate Expert’s Use of the Sales Comparison Approach is Permissible" meta: "og:description": "Real estate expert prepared an appraisal report for each of the Plaintiffs' properties in accordance with professional appraisal standards" "og:title": "Real Estate Expert’s Use of the Sales Comparison Approach is Permissible" author: "Expert Witness Profiler" description: "Real estate expert prepared an appraisal report for each of the Plaintiffs' properties in accordance with professional appraisal standards" --- # Real Estate Expert’s Use of the Sales Comparison Approach is Permissible Posted on March 19, 2025 by Expert Witness Profiler Residents near a biomass power plant in Madison County, Georgia, owned and operated by the defendants, allege that the plant’s noise, vibrations, light, smoke, and soot are negatively impacting their property values. They have filed nuisance and negligence claims. The Defendants are challenging the admissibility of the Plaintiffs’ expert witness, real estate appraiser [Kenneth Cantrell](https://expertwitnessprofiler.com/expert-witness/Kenneth-Cantrell/1563292), under [Federal Rule of Civil Procedure 702](https://www.law.cornell.edu/rules/fre/rule_702#:~:text=Rule%20702%20sets%20forth%20the,is%20a%20relatively%20narrow%20inquiry.). While not disputing Cantrell’s qualifications, the Defendants argued that his appraisal, which assesses the decrease in property values due to plant noise, lacks sufficient factual basis and employs an unreliable methodology. ## **Real Estate Expert Witness** [Kenneth Cantrell](https://expertwitnessprofiler.com/expert-witness/Kenneth-Cantrell/1563292), a Georgia-based certified real estate appraiser, boasts a career spanning more than thirty years. Cantrell possesses a robust educational background in real estate and finance, demonstrated by his successful completion of coursework covering essential areas such as real estate valuation, finance, law, brokerage, and investment analysis. Furthermore, he has consistently pursued advanced professional development, either completing or successfully challenging numerous courses offered by esteemed organizations like the Appraisal Institute (AI) and the Commercial Investment Real Estate Council (CI), underscoring his commitment to maintaining a high level of expertise. [Want to know more about the challenges Kenneth Cantrell has faced? Get the full details with our Challenge Study report.](https://expertwitnessprofiler.com/order/add?eId=1563292&pId=3) ## **Discussion by the Court** Real estate appraiser Kenneth Cantrell used the sales comparison approach to assess the impact of the biomass plant on the Plaintiffs’ property values, claiming his work adheres to the Appraisal Institute’s Uniform Standards of Professional Appraisal Practice and the Appraisal Institute’s Code of Professional Ethics and Standards of Professional Appraisal Practice. The Defendants challenged his methodology on three main points: 1) They argued he failed to properly verify sales data for comparable properties. The Plaintiffs countered that Cantrell’s associate verified the data, which is permissible. 2) The Defendants criticized the distance between comparable and appraised properties. The Plaintiffs responded that the rural setting justified the use of such comparables, under applicable appraisal standards. 3) The Defendants claimed Cantrell relied on a biased report about the Madison plant’s impact. However, the Court found Cantrell’s use of that study as a factor, to determine the size of the impacted area, was permissible. The Court concluded that the Defendants’ criticisms pertain to the weight of Cantrell’s testimony, not its admissibility. Finding that Cantrell’s testimony is based on sufficient facts and reliable methodology, and would assist the jury, the Court denied the Defendants’ motion to exclude his testimony. ## **Held** The Court denied the Defendants’ motion to exclude Kenneth Cantrell’s testimony. ## **Key Takeaways:** - The Court recognized that in rural settings, broader geographic comparisons for real estate appraisals may be necessary and permissible, according to professional appraisal standards. - Criticisms regarding the methodology, data verification, and comparable properties were deemed to affect the weight of the appraisal evidence, not its admissibility. ## **Case Details:** --- ## **You Might Also Like** ![Human Resources Expert Allowed to Opine on Termination](https://ewp-blog.expertwitnessprofiler.org/wp-content/uploads/2026/04/blog-pic-640X480-2026-04-22T200052.311.jpg) [**Human Resources Expert Allowed to Opine on Termination**](https://expertwitnessprofiler.com/real-estate-experts-use-of-the-sales-comparison-approach-is-permissible/human-resources-expert-allowed-to-opine-on-termination)![Neuropsychology Expert Not Allowed to Opine on Cognitive Decline](https://ewp-blog.expertwitnessprofiler.org/wp-content/uploads/2026/04/blog-pic-640X480-2026-04-22T144728.528.jpg) [**Neuropsychology Expert Not Allowed to Opine on Cognitive Decline **](https://expertwitnessprofiler.com/real-estate-experts-use-of-the-sales-comparison-approach-is-permissible/neuropsychology-expert-not-allowed-to-opine-on-cognitive-decline)![Human Factors Expert Not Allowed to Opine on the Tile](https://ewp-blog.expertwitnessprofiler.org/wp-content/uploads/2026/04/blog-pic-640X480-2026-04-21T191749.960.jpg) [**Human Factors Expert Not Allowed to Opine on the Tile**](https://expertwitnessprofiler.com/real-estate-experts-use-of-the-sales-comparison-approach-is-permissible/human-factors-expert-not-allowed-to-opine-on-the-tile)![Insurance Expert Not Allowed to Opine on Legal Duties](https://ewp-blog.expertwitnessprofiler.org/wp-content/uploads/2026/04/blog-pic-640X480-2026-04-21T155751.487.jpg) [**Insurance Expert Not Allowed to Opine on Legal Duties**](https://expertwitnessprofiler.com/real-estate-experts-use-of-the-sales-comparison-approach-is-permissible/insurance-expert-not-allowed-to-opine-on-legal-duties)![Law And Legal Expert Not Allowed to Opine on Contract Formation](https://ewp-blog.expertwitnessprofiler.org/wp-content/uploads/2026/04/blog-pic-640X480-2026-04-20T213123.718.jpg) [**Law And Legal Expert Not Allowed to Opine on Contract Formation**](https://expertwitnessprofiler.com/real-estate-experts-use-of-the-sales-comparison-approach-is-permissible/law-and-legal-expert-not-allowed-to-opine-on-contract-formation)