Daubert Objection Raised Only at Trial Is Untimely, Says 1st Circuit

The First Circuit has held that a Daubert objection raised only at trial came too late. From the opinion in Feliciano-Hill v. Principi, No. 04-1072 (1st Cir. Feb. 22, 2006):

The district court denied [appellant's] motion both because it was untimely -- [appellant] waited until the moments before [the expert's] testimony to object, even though she had received the doctor's report five months earlier -- and because [the expert's] report and proposed testimony met the applicable standard. The district court was correct on both grounds.

Parties have an obligation to object to an expert's testimony in a timely fashion, so that the expert's proposed testimony can be evaluated with care. [Appellant] did not make a timely motion here and has not offered any reason for her delay. The district court was on firm ground in refusing her motion as untimely.

Would such a rule make a certain amount of practical sense? Perhaps. Is it consistent with Fed. R. Evid. 103, which seems to say that evidentiary objections at trial are sufficient to preserve error? Less clear. Did the objecting party in Feliciano-Hill miss a court-imposed pretrial deadline? Not that the opinion mentions.