Admissibility of novel scientific evidence: Frye v. United States

AdditCourts in the United States may employ various standards to determine the admissibility of novel scientific evidence. From 1923 to 1993, the dominant standard for determining admissibility of such evidence at both state and federal levels was the general acceptance test. This standard stems from the seminal case Frye v. United States, in which a federal appeals court held that expert testimony was admissible only if the scientific principle. It became general practice in most courts for almost three-quarters of a century.

Court of Appeals for the District of Columbia: Admissibility of novel scientific evidence

Significance: This appellate ruling held that polygraph results are inadmissible in court. The appeals court also introduced a new standard for the admissibility of new or novel scientific evidence in court. Additionally, courts in the United States may employ various standards to determine the admissibility of novel scientific evidence. From 1923 to 1993, the dominant standard for determining admissibility of such evidence.

This standard stems from the seminal case Frye v. United States, in which a federal appeals court held that expert testimony was admissible.

Admissibility of novel scientific evidence: Background of the Case and Frye Requirements

Frye concerned the admissibility of a systolic pressure deception test, a precursor of the polygraph, in a murder case.  Specifically, the trial court precluded the defendant, James Alphonzo Frye, from introducing expert testimony concerning the deception test as well as evidence about his truthfulness through the test.

In a unanimous decision, the appeals court concluded that the deception test had not yet gained sufficient general acceptance. Hence, under the Frye standard, it is not sufficient that a sole expert, or even several experts. Rather, Frye imposes a unique hurdle—that is, the technique or device must be generally accepted by the relevant scientific community.

The Frye standard conditions the admissibility of expert testimony in court on acceptance of other scientists within the field. In order to meet the Frye standard, novel scientific evidence must be interpreted by a court as generally accepted by a meaningful segment of the relevant scientific community. In practice, the relevant scientific community often includes a sufficient number of individual experts within a specific field.

Issues in Forensic Science: Frye v. United States

 

Since the ruling in Frye v. United States in 1923, the Frye standard has been applied to numerous forensic science techniques in both criminal and civil cases. This include DNA (deoxyribonucleic acid) analysis, human leukocyte antigen (HLA) paternity testing and voiceprint analysis.

Admissibility of novel scientific evidence: new scientific techniques

The Frye standard has generated criticism concerning whether it is flexible enough to adapt to novel scientific evidence. In 1993, in the case Daubert v. Merrell Dow Pharmaceuticals, the U.S. Supreme court rejected Frye and modified the standard for the admissibility of expert testimony in federal courts.

In Daubert, the Court held that Congress intended for the Federal Rules of Evidence, specifically Rule 702, to supersede Frye. Rule 702 allows the introduction of scientific, technical, or other specialized knowledge by a qualified expert if such knowledge.  According to the highest court, Frye’s general acceptance test was to be only one indicator of reliability. Despite the federal court’s shift in position, the Frye standard remains the standard for admission of scientific evidence in a number of state jurisdictions.

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