The Daubert Standard is a critical rule of evidence used in the United States legal system. It serves as a guideline for a judge to determine whether a proposed expert witness’s testimony is both relevant and reliable. Introduced through the landmark Supreme Court case Daubert v. Merrell Dow Pharmaceuticals, Inc., this standard helps ensure that only qualified expert testimony is presented to the jury.
Origin and Historical Context
The Daubert Standard was established in the 1993 Supreme Court case Daubert v. Merrell Dow Pharmaceuticals, Inc. The case centered on the admissibility of expert testimony regarding the alleged birth defects caused by a pharmaceutical drug called Bendectin. The Supreme Court ruled that the trial judge must act as a “gatekeeper” and evaluate whether the expert’s testimony is scientifically valid and applicable.
In 1999, Kumho Tire Co. v. Carmichael extended the Daubert Standard to all expert testimony, not just scientific testimony. This case involved a tire blowout expert, and the Supreme Court affirmed that the Daubert criteria apply broadly to technical and other specialized knowledge.
Elements of the Daubert Test
The Daubert Standard evaluates several factors to determine the admissibility of expert testimony:
- Testability: Can the theory or technique be tested and has it been tested?
- Peer Review and Publication: Has the theory or technique been subjected to peer review and publication?
- Error Rate: What is the known or potential error rate?
- Standards: Are there standards controlling the technique’s operation?
- Acceptance: Is the theory or technique generally accepted in the relevant scientific community?
Daubert vs. Frye and Robinson Standards
The Frye Standard, established in Frye v. United States (1923), requires that scientific evidence be “generally accepted” by the scientific community. The Robinson Standard is a less rigid version of the Frye Standard, focusing more on the qualifications of the expert rather than the scientific validity of the testimony.
Applicability in Federal and State Courts
The Daubert Standard is the law in federal courts and in over half of the U.S. states. However, some states continue to adhere to the Frye or Robinson Standards. This diversity can lead to variations in how expert testimony is handled in different jurisdictions.
Examples and Case Applications
- Daubert Example: In the original Daubert case, the court evaluated medical expert testimony regarding the drug Bendectin to determine its scientific reliability.
- Kumho Tire Example: The court assessed the reliability of an engineering expert’s testimony concerning tire defect analysis.
FAQs
What Does the Daubert Standard Do?
Who Decides if Testimony Meets the Daubert Standard?
How Does the Daubert Standard Impact Legal Proceedings?
Summary
The Daubert Standard is a cornerstone of American legal procedures concerning expert testimony, emphasizing the importance of scientific validity and reliability. Since its establishment, it has shaped the role of expert witnesses, ensuring that their contributions to court proceedings are sound and credible.
References
- Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993).
- Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999).
- Frye v. United States, 293 F. 1013 (D.C. Cir. 1923).
By encompassing these detailed aspects, readers will gain a comprehensive understanding of the Daubert Standard and its critical role in the legal system.
