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Court of Appeals for the D.C. Circuit • 1923

Frye v. United States

293 F. 1013 | 54 App. D.C. 46 | 34 A.L.R. 145 | 1923 U.S. App. LEXIS 1712

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Takeaway

In short, Frye established the general-acceptance test: novel scientific evidence is admissible only when its underlying principle has gained general acceptance in its relevant scientific field.

Background

Frye was convicted of second-degree murder. Before trial, he underwent a systolic blood-pressure “deception test,” an early form of lie-detector examination. The proposed theory was that a person’s blood pressure changes in a distinctive way when he consciously lies out of fear of detection, as opposed to when he merely feels anxious about being examined.

At trial, Frye offered the examiner as an expert witness to report the test results. After the government objected, the trial court excluded the testimony. Frye also asked to have the witness administer the test before the jury, and the court denied that request. Frye appealed, challenging the exclusion of this evidence.

Issues

Issue #1

Whether expert testimony based on the systolic blood-pressure deception test was admissible to show that Frye was telling the truth.

Holding

No. The test had not gained sufficient general acceptance and scientific recognition among the relevant physiological and psychological authorities to support admission of testimony based on it.

Reasoning

The court accepted the general proposition that expert opinion may assist the factfinder when a subject lies outside ordinary experience and requires specialized scientific, technical, or professional knowledge. But that general rule does not make every asserted scientific development a proper basis for expert testimony.

A court must determine when a scientific principle has moved beyond the experimental stage and become sufficiently demonstrable to carry evidentiary force. Although courts may admit expert conclusions derived from well-recognized scientific principles or discoveries, the underlying principle must first be adequately established.

The relevant standard is whether the scientific principle has gained general acceptance in the particular field to which it belongs. This requirement prevents a jury from receiving conclusions drawn from a method that remains too novel, unverified, or disputed within the applicable scientific community.

The systolic blood-pressure deception test had not yet achieved the necessary standing or recognition among physiological and psychological authorities. Because the premise that blood-pressure patterns reliably distinguish truth from deliberate deception lacked general acceptance, the trial court properly excluded both the examiner’s proposed testimony and the requested in-court test.