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203 Fed. 1013 (1923)

Frye vs. United States (1923) established the standard for admissibility of an expert's scientific testimony which lasted for more than 70 years before Daubert. The Frye test of admissibility was based on a logical conclusion that scientific evidence should be generally accepted in the specific field of knowledge involved. Although effective, though, Frye tended to preclude the admissibility of uncommon or unusual scientific evidence in all Federal and many state courts. Under Frye, it was noted that expert testimony must be based upon a "scientific principle or discovery.... initially established to have gained acceptance in the particular field in which it belongs."

One of the more interesting dilemmas when considering expert witness testimony by forensic vocational rehabilitation, life care planning and economic experts, though, is the fact that the Daubert court was silent on the matter of the social sciences in which vocational rehabilitation, life care planning and economic experts would be placed. Psychological research, for instance, can range from exquisitely designed, highly controlled experimental work to mere theory which barely rises above the definition of speculation. Distinguishing lines between good, bad, and non-science are hazy, at best.

Still, there exists proven methodologies customarily relied upon by vocational rehabilitation, life care planning and economic experts which are reliable and provide for valid analysis of damage claims in civil litigation.

Ref.: http://www.legaldamages.com/document/articles/damages.html

Frye v. United States (1923) - U.S. Court of Appeals of District of Columbia - This is the original decision dealing with scientific evidence and its admissibility in court. Frye was accused of murdering a doctor. At the time, he took a unigraph, a precursor to the polygraph. The unigraph measured only the cardiovascular activities of the body. The examiner reported Frye to be truthful, and Frye moved to have that evidence admitted in court. The court ruled that before any scientific evidence could be admitted into the court of law it must first be accepted by the scientific community. At that time, there were no studies done on unigraphs or polygraphs, so the evidence was not admitted.

Ref.: http://people.howstuffworks.com/lie-detector10.htm