Daubert v. Merrell Dow Pharmaceuticals, Inc.
Headline: Scientific evidence rules changed as the Court rejects the old "general acceptance" test and lets federal judges screen expert scientific testimony for reliability, affecting who can present new science at trial.
Holding: The Court held that federal trials need not follow the old "general acceptance" test and instead require judges to screen expert scientific testimony for scientific reliability and relevance before juries may hear it.
- Gives federal judges power to exclude unreliable scientific expert testimony.
- Makes it easier for some novel scientific evidence to reach juries if shown reliable.
- Increases pretrial disputes and hearings over expert testimony.
Summary
Background
Two minor children born with serious birth defects and their parents sued a drug maker, saying the mothers' use of the anti-nausea drug Bendectin caused the defects. The company removed the suits to federal court and moved for summary judgment. The District Court excluded the plaintiffs' experts under a "general acceptance" rule and relied on many published human studies finding no link; the Ninth Circuit affirmed.
Reasoning
The Court addressed what standard federal judges must use to admit scientific expert testimony. It held that the old Frye "general acceptance" test is not required under the Federal Rules of Evidence. Instead, Rule 702 gives judges a gatekeeping role: they must admit only expert testimony that is relevant and rests on reliable, scientific grounds. Judges may consider testability, peer review and publication, error rates, standards, and how well the methods fit the case. The Court vacated the Ninth Circuit's judgment and remanded for reconsideration under this standard.
Real world impact
The ruling changes how trials handle scientific experts. Trial judges now have clearer authority to exclude unreliable scientific testimony before juries hear it, while also allowing well-supported new science to be admitted even if not yet widely accepted. The decision will increase pretrial challenges about experts and affect what scientific claims reach juries. The opinion decides admissibility, not whether the drug did or did not cause the injuries.
Dissents or concurrances
Chief Justice Rehnquist, joined by Justice Stevens, agreed Frye was displaced but warned judges should not be required to act as amateur scientists and cautioned that the Court's guidance may be vague in practice.
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