Frye v. United States
293 F. 1013 (1923) (1923)
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Rule of Law:
For scientific evidence to be admissible in court, the principle or discovery from which the deduction is made must be sufficiently established to have gained general acceptance in the particular field to which it belongs.
Facts:
- Frye was accused of committing murder.
- Prior to his trial, Frye submitted to a scientific test known as the systolic blood pressure deception test, an early form of a lie detector.
- The test was based on the theory that the conscious effort required to tell a lie causes a detectable rise in a person's systolic blood pressure.
- The results of Frye's test purportedly indicated that he was being truthful when denying his involvement in the crime.
Procedural Posture:
- Frye was prosecuted for murder in the Supreme Court of the District of Columbia (the trial court).
- During the trial, the defense offered expert testimony regarding the results of a systolic blood pressure deception test administered to Frye.
- The trial court sustained the prosecution's objection and excluded the expert testimony.
- The defense then offered to have the test performed on Frye in the presence of the jury, a request the trial court also denied.
- The jury convicted Frye of murder in the second degree.
- Frye, as the appellant, appealed the judgment to the Court of Appeals of the District of Columbia.
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Issue:
Is expert testimony detailing the results of a systolic blood pressure deception test admissible as evidence if the underlying scientific principle has not yet gained general acceptance in the relevant scientific community?
Opinions:
Majority - Van Orsdrp, Associate Justice.
No. Expert testimony based on a scientific principle is inadmissible unless the principle is 'sufficiently established to have gained general acceptance in the particular field in which it belongs.' The court reasoned that while expert testimony is permissible when a subject is beyond the common knowledge of jurors, a higher standard applies to evidence derived from a novel scientific principle. The court must be able to recognize the principle as having crossed the line from the 'experimental' to the 'demonstrable' stage. The court concluded that the systolic blood pressure deception test had not yet achieved the necessary standing and scientific recognition among physiological and psychological authorities to justify its admission as evidence.
Analysis:
This landmark decision established the 'Frye test,' or the 'general acceptance' standard, for the admissibility of novel scientific evidence in American courts. This standard became the dominant rule in federal and most state jurisdictions for the next 70 years. The Frye test acts as a conservative judicial check, delegating the gatekeeping role for scientific evidence to the relevant scientific community rather than the judge. This approach prevents courts from being flooded with evidence based on unproven or fringe scientific theories until a consensus of experts in the field validates the underlying methodology.
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