Frye v. United States
- Court
- Court of Appeals for the D.C. Circuit (Federal circuit court)
- Decided
- 1923
- Citation
- 293 F. 1013 (D.C. Cir. 1923)
- Standard applied
- Frye — general acceptance in the relevant field
What the court held
Expert testimony deduced from a scientific principle is admissible only where the principle from which the deduction is made has gained general acceptance in the particular field to which it belongs. The court affirmed the exclusion of testimony based on a systolic blood-pressure deception test, the forerunner of the polygraph, because it had not achieved that standing.
Why
The court accepted that courts will go a long way in admitting expert testimony built on a well-recognised scientific principle, but located the dividing line at the point where a principle crosses from the experimental to the demonstrable. Because the deception test had not yet gained recognition among physiological and psychological authorities, testimony deduced from it was not admissible.
“the thing from which the deduction is made must be sufficiently established to have gained general acceptance in the particular field in which it belongs.”
Our reading — not the court’s words
Why this matters in practice
A century on, Frye still governs expert evidence in a minority of states, so whether it or Rule 702 applies is a jurisdictional question a forensic examiner should settle before writing a report rather than after. The practical difference matters for digital work: Frye asks whether the community accepts the technique and is largely indifferent to how well it was applied here, while Rule 702 as read by Joiner scrutinises exactly that application. A novel extraction method can therefore fail in a Frye state while surviving in a federal court, and a sloppily applied standard tool can do the reverse.
This paragraph is Legal Cyber Academy’s editorial assessment of the decision’s practical importance. The court said none of it. For what the court actually said, read the opinion.
Additional detail
Tags: Frye · general acceptance · novel technique
Cited 4,222times in CourtListener’s corpus at the time this entry was compiled. Treat it as a rough measure of influence, not of correctness.
Other decisions on expert admissibility
- Daubert v. Merrell Dow Pharmaceuticals, Inc.Supreme Court of the United States · 1993The Court held that Frye's "general acceptance" test did not survive the Federal Rules of Evidence and is not a precondition to admitting scientific expert test…
- Kumho Tire Co. v. CarmichaelSupreme Court of the United States · 1999The trial judge's gatekeeping obligation under Rule 702 is not confined to “scientific” testimony; it applies to all expert testimony, including testimony resti…
- General Electric Co. v. JoinerSupreme Court of the United States · 1997A decision to admit or exclude expert testimony is reviewed for abuse of discretion, not under any more stringent standard because the ruling is outcome-determi…
- United States v. UlbrichtCourt of Appeals for the Second Circuit · 2017The Second Circuit affirmed the exclusion of both of the defendant's proposed expert witnesses in the Silk Road prosecution because his expert notices were unti…
- Lorraine v. Markel American Insurance Co.District Court, D. Maryland · 2007Neither party's electronic exhibits could be considered because none was authenticated: e-mails were simply attached to the motions rather than supported by aff…
- Commonwealth v. NevelsSuperior Court of Pennsylvania · 2019The Superior Court affirmed the judgment of sentence, upholding the trial court's decision to admit an FBI agent's expert testimony on historical cell-site anal…
Summarised from the opinion as retrieved from CourtListener. Reference material, not legal advice. Back to the repository.