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Keywords

plaintiffliabilityappealtrialtestimonyaffidavitsummary judgmentrelevanceadmissibility
appealtrialtestimonyaffidavitsummary judgmentrespondent

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Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579, 113 S.Ct. 2786, 125 L.Ed.2d 469, 61 USLW 4805, 27 U.S.P.Q.2d 1200, 23 Envtl. L. Rep. 20,979, 37 Fed. R. Evid. Serv. 1, Prod.Liab.Rep. (CCH) P 13,494

Facts

Petitioners Jason Daubert and Eric Schuller, minor children born with serious birth defects, along with their parents, sued Merrell Dow Pharmaceuticals, alleging that the birth defects were caused by the mothers' ingestion of Bendectin, an antinausea drug. The District Court granted summary judgment to the pharmaceutical company based on an expert's affidavit stating that Bendectin had not been shown to be a risk factor for human birth defects. The plaintiffs presented testimony from eight other experts, but the court ruled that their evidence did not meet the 'general acceptance' standard for admissibility.

Petitioners Jason Daubert and Eric Schuller are minor children born with serious birth defects. They and their parents sued respondent in California state court, alleging that the birth defects had been caused by the mothers' ingestion of Bendectin, a prescription antinausea drug marketed by respondent.

Issue

Whether the 'general acceptance' standard for admitting expert scientific testimony, established in Frye v. United States, remains valid after the enactment of the Federal Rules of Evidence.

The petition for certiorari in this case presents two questions: first, whether the rule of Frye v. United States, 54 App.D.C. 46, 293 F. 1013 (1923) , remains good law after the enactment of the Federal Rules of Evidence; and second, if Frye remains valid, whether it requires expert scientific testimony to have been subjected to a peer review process in order to be admissible.

Rule

The Federal Rules of Evidence, particularly Rule 702, govern the admissibility of expert testimony, requiring that it be based on reliable principles and relevant to the case at hand, without necessitating 'general acceptance' in the scientific community.

The Federal Rules of Evidence, not Frye, provide the standard for admitting expert scientific testimony in a federal trial.

Analysis

The Supreme Court determined that the lower courts had improperly focused on the 'general acceptance' standard, which was superseded by the Federal Rules of Evidence. The Court emphasized that Rule 702 requires trial judges to assess the reliability and relevance of expert testimony, allowing for a more flexible approach than the rigid Frye standard. The Court outlined various factors that judges should consider when evaluating scientific testimony, including testing, peer review, and error rates.

The inquiries of the District Court and the Court of Appeals focused almost exclusively on 'general acceptance,' as gauged by publication and the decisions of other courts.

Conclusion

The Supreme Court vacated the judgment of the Court of Appeals and remanded the case for further proceedings consistent with its opinion, establishing that the 'general acceptance' standard is not required for the admissibility of scientific evidence under the Federal Rules of Evidence.

The judgment of the Court of Appeals is vacated, and the case is remanded for further proceedings consistent with this opinion.

Who won?

The prevailing party was Merrell Dow Pharmaceuticals, as the Supreme Court's ruling vacated the lower court's decision that had favored the plaintiffs and remanded the case for further proceedings.

The District Court granted respondent summary judgment based on a well-credentialed expert's affidavit concluding, upon reviewing the extensive published scientific literature on the subject, that maternal use of Bendectin has not been shown to be a risk factor for human birth defects.

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