Quick Summary
Jason Daubert and Eric Schuller (plaintiffs) sued Merrell Dow Pharmaceuticals (defendant), claiming Bendectin caused birth defects. The dispute centered on whether expert testimony based on scientific evidence required ‘general acceptance’ for admissibility.
The Supreme Court ruled that under Rule 702 of the Federal Rules of Evidence, expert testimony must be relevant and reliable but does not need to meet ‘general acceptance.’ The decision shifted the focus from widespread acceptance to a more flexible reliability standard.
Facts of the Case
Jason Daubert and Eric Schuller (plaintiffs), both born with birth defects, along with their parents, initiated legal action against Merrell Dow Pharmaceuticals (defendant). They alleged that the defendant’s product, Bendectin, was responsible for causing these defects.
The plaintiffs presented the testimony of eight scientific experts who asserted a causal link between Bendectin and birth defects. However, their testimony was challenged based on the acceptance of the scientific methods used in their conclusions.
The core dispute revolved around the admissibility of expert testimony derived from scientific techniques that had not gained ‘general acceptance’ within the scientific community. This raised significant questions about the standards for admitting expert scientific evidence in federal trials.
Procedural History
- The plaintiffs filed suit against Merrell Dow Pharmaceuticals alleging that Bendectin caused birth defects.
- The district court granted summary judgment in favor of Merrell, ruling that the scientific evidence presented by the plaintiffs was inadmissible as it did not meet the ‘general acceptance’ standard.
- The United States Court of Appeals for the Ninth Circuit affirmed the decision, maintaining the ‘general acceptance’ criterion for admissibility of scientific evidence.
- The United States Supreme Court granted certiorari to address the proper standard for admitting expert scientific testimony.
I.R.A.C. Format
Issue
Whether the ‘general acceptance’ standard is the sole criterion for determining the admissibility of expert scientific testimony under the Federal Rules of Evidence.
Rule of Law
The Federal Rules of Evidence, particularly Rule 702, stipulate that scientific evidence must be relevant and reliable to be admissible, without requiring ‘general acceptance’ within the scientific community.
Reasoning and Analysis
The Supreme Court clarified that the ‘general acceptance’ standard from Frye v. United States was not a necessary condition for admissibility under the Federal Rules of Evidence. The Court emphasized that Rule 702 requires expert testimony to be grounded in scientifically valid principles that are relevant to the facts at issue.
The testimony must be derived from a reliable scientific method and assist the trier of fact. The Court outlined factors such as testability, peer review, error rates, and standards controlling the operation of scientific techniques to determine reliability. While ‘general acceptance’ within the scientific community could be a factor, it was not the sole consideration.
The trial judge plays a gatekeeping role to ensure that any expert testimony admitted is based on a reliable foundation and is relevant to the task at hand, guided by Rule 104(a) of the Federal Rules of Evidence.
Conclusion
The Supreme Court held that ‘general acceptance’ is not a mandatory prerequisite for admitting expert scientific evidence. The appropriate standard is set by Federal Rule of Evidence 702, which requires that such evidence or testimony must be both relevant and reliable.
Key Takeaways
- The ‘general acceptance’ standard from Frye does not govern the admissibility of expert scientific testimony under the Federal Rules of Evidence.
- Rule 702 requires that expert scientific testimony be relevant and reliable to assist the trier of fact.
- The trial judge serves as a gatekeeper to ensure the admissibility standards are met, in line with Rule 104(a).
- Factors such as testability, peer review, known error rates, and standards control contribute to determining the reliability of scientific evidence.
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