In Frye v. United States, the Court of Appeals of the District of Columbia affirmed a trial court's exclusion of lie detector test results on the ground that such tests had not been "generally accepted" by the scientific community. The Frye rule, or "general acceptance" standard, quickly became the dominant test for the admission of scientific evidence. Decided in 1923, Frye governed evidentiary decisions in a majority of federal circuits for the next seventy years. The adoption of the Federal Rules of Evidence in 1975, however, prompted several judges to question the validity of Frye. Since the enactment of the Rules debate has surrounded the standards governing the admissibility of expert testimony.
Kimberly A. Satterwhite,
Taking the Sizzle Out of the Frye Rule: Daubert v. Merrell Dow Pharmaceuticals Opens the Door to Novel Expert Testimony,
U. Rich. L. Rev.
Available at: http://scholarship.richmond.edu/lawreview/vol28/iss2/8