James Alphonso Frye was on trial for murder in the District of Columbia. The defense sought to introduce the results of an early systolic blood pressure deception test, a precursor to the polygraph, to show Frye was telling the truth when he denied guilt. The trial court excluded the evidence, and Frye was convicted of second-degree murder. On appeal, Frye argued the scientific test results should have been admitted through expert testimony.
When may results derived from a scientific technique be admitted into evidence through expert testimony?
Scientific evidence based on a novel principle or discovery is admissible only if the principle or technique has gained general acceptance in the particular field to which it belongs. A court may recognize established scientific principles, but it should exclude techniques that have not yet crossed the line from experiment to demonstrated acceptance.
The court held the deception test evidence was properly excluded because the systolic blood pressure test had not gained sufficient standing and scientific recognition among physiological and psychological authorities. Therefore, the expert testimony based on that test was inadmissible.
The court acknowledged that courts often admit expert testimony drawn from well-recognized scientific principles, but stressed that novel scientific methods require a threshold showing of acceptance in the relevant scientific community. The deception test had not yet achieved that level of recognition and remained too experimental to justify admission. Because the scientific basis was not sufficiently established, the trial judge acted properly in excluding it.
Frye created the long-dominant 'general acceptance' test for admissibility of novel scientific evidence. It shaped evidence law for decades until the Supreme Court held that the Federal Rules of Evidence superseded Frye in federal courts in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993); see also General Electric Co. v. Joiner, 522 U.S. 136 (1997), and Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999). Many state courts initially followed Frye, and some still use a Frye-type general-acceptance standard for certain expert evidence.
Daubert v. Merrell Dow Pharmaceuticals, 509 U.S. 579 (1993) |
Verified |
General Electric Co. v. Joiner, 522 U.S. 136 (1997) |
Abstain |
Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999) |
Abstain |
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