The Daubert Standard, often referred to as the Daubert Trilogy, serves as the criterion by which a trial judge evaluates the admissibility of expert testimony. This standard establishes the criteria for expert witnesses to meet to be able to provide testimony:
- Qualification of the Expert Witness: The expert must possess the requisite knowledge, skills, experience, training, or education. This expertise should enable the expert to present scientific, technical, or other specialized knowledge in a manner that aids the trier of fact in comprehending the evidence or reaching a factual determination.
- Foundation in Facts and Data: The expert’s testimony must be founded on substantial and pertinent facts and data related to the case.
- Reliability of Principles and Methods: The testimony should stem from reliable principles and methodologies that have gained acceptance within the relevant scientific or professional community.
- Application of Principles and Methods: The expert must have consistently and dependably applied the aforementioned principles and methods to the specific facts of the case.
In essence, the Daubert Standard functions as a litmus test to ascertain the reliability of a particular technique or theory, its acknowledgement within the relevant scientific community, and assesses the likelihood of error when assessing the credibility of expert testimony.
The Daubert Trilogy comprises three pivotal United States Supreme Court cases that enunciated and elaborated upon the Daubert standard:
- Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993): This landmark case gave rise to the Daubert standard which was a flexible reliability standard incorporated by Rule 702 of the Federal Rules of Evidence, insisting on the role of judges as gatekeepers. It mandates that expert witnesses must present testimony supported by substantial scientific evidence. This criterion extends to both civil and criminal proceedings.
- General Electric Co. v. Joiner (1997): In instances where a District Court determines that an expert’s conclusions lack a satisfactory foundation in the evidence they relied upon, exclusion of the testimony is justifiable. When an appellate court reviews a trial court’s decision regarding the admission of expert testimony, the proper standard for assessment is the abuse-of-discretion standard of review.
- Kumho Tire Co. v. Carmichael (1999): This case underscores that the Daubert gatekeeping requirement seeks to ensure the reliability and relevance of all expert testimony, regardless of its scientific underpinning or lack thereof.
In summary, the Daubert Standard, encapsulated within the Daubert Trilogy, establishes the criteria for the evaluation of the admissibility of expert testimony. It underscores the need for expert witnesses to possess relevant qualifications and generate sound testimony based on reliable facts and data.
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