Daubert Trilogy
Definition
The three US Supreme Court decisions that together define the federal standard for expert testimony admissibility: Daubert v. Merrell Dow Pharmaceuticals (1993), General Electric Co. v. Joiner (1997), and Kumho Tire Co. v. Carmichael (1999).
- Case 1
- Daubert v. Merrell Dow Pharmaceuticals, 1993
- Case 2
- General Electric Co. v. Joiner, 1997
- Case 3
- Kumho Tire Co. v. Carmichael, 1999
- Court
- US Supreme Court
Common questions
What did Kumho Tire add to the standard that Daubert alone did not establish?+
Kumho Tire extended the trial judge's gatekeeping obligation beyond scientific testimony to all expert testimony, including technical and other specialised knowledge such as engineering or tool-mark analysis, confirming that the reliability inquiry applies broadly rather than only to evidence framed as hard science.
What did Joiner clarify about how appellate courts review a trial judge's admissibility ruling?+
General Electric Co. v. Joiner established that appellate courts review a trial judge's decision to admit or exclude expert testimony under the deferential abuse-of-discretion standard rather than reviewing the reliability question fresh, making trial-level Daubert rulings hard to overturn on appeal.
Related terms
- Abuse of Discretion
- The standard of appellate review established by Joiner for Daubert rulings. An appellate court will reverse a trial judge's gatekeeping decision only...
- Daubert Gatekeeping
- The judicial function under Daubert v. Merrell Dow Pharmaceuticals (1993) and Federal Rules of Evidence Rule 702, requiring the trial judge to...
- Error Rate
- One of the Daubert factors: the known or potential rate at which a method produces false positives or false negatives, and whether...
- Federal Rule of Evidence 702
- The US federal rule governing expert testimony. As amended through 2023, it requires that expert opinion be based on sufficient facts or...
- Frye Standard
- The US legal test for admissibility of scientific evidence, originating from Frye v. United States (1923), which required that a technique be...