Daubert standard (California) · Go Syfert
← California issues

Daubert standard in California

18 California opinions name it 3 courts 1995–2023 5 in the last five years

The cases below were cited by California courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (23)

CaseFollowedCited
People v. Daveggio & Michaudgreen
cal · 2018 · cited in 2 California opinions naming this issue, 2023–2023
2 sentences

2023(See People v. Daveggio and Michaud (2018) 4 Cal.5th 790, 831, fn. 7 .) 41. dispelling any “ ‘ “ ‘misleading aura of certainty’ ” ’ ” regarding the process.

2023(See People v. Daveggio and Michaud (2018) 4 Cal.5th 790, 831, fn. 7 .) 41. dispelling any “ ‘ “ ‘misleading aura of certainty’ ” ’ ” regarding the process.

22
People v. Leahygreen
cal · 1994 · cited in 2 California opinions naming this issue, 2011–2014
2 sentences

2014(People v. Leahy (1994) 8 Cal.4th 587, 593-604 [ 34 Cal.Rptr.2d 663 , 882 P.2d 321 ] [holding that the Kelly prongs survived Daubert in this state].) In addition, our opinion in Sargon Enterprises, Inc. v. University of Southern California, supra, 55 Cal.4th 747 did not, by using the term “gatekeeper,” indicate any move away from the Kelly test toward the federal Daubert standard.

2014(People v. Leahy (1994) 8 Cal.4th 587, 593-604 [ 34 Cal.Rptr.2d 663 , 882 P.2d 321 ] [holding that the Kelly prongs survived Daubert in this state].) In addition, our opinion in Sargon Enterprises, Inc. v. University of Southern California, supra, 55 Cal.4th 747 did not, by using the term “gatekeeper,” indicate any move away from the Kelly test toward the federal Daubert standard.

22
Sargon Enterprises, Inc. v. University of Southern Californiagreen
cal · 2012 · cited in 3 California opinions naming this issue, 2013–2018
2 sentences

2018(Sargon Enterprises, Inc. v. University of Southern California (2012) 55 Cal.4th 747, 770-771 .) The Kelly/Daubert rule conditions the admissibility of evidence based on a new scientific method on a showing that the method is generally accepted as reliable in the relevant scientific community.

2014(People v. Leahy (1994) 8 Cal.4th 587, 593-604 [ 34 Cal.Rptr.2d 663 , 882 P.2d 321 ] [holding that the Kelly prongs survived Daubert in this state].) In addition, our opinion in Sargon Enterprises, Inc. v. University of Southern California, supra, 55 Cal.4th 747 did not, by using the term “gatekeeper,” indicate any move away from the Kelly test toward the federal Daubert standard.

13
People v. Venegasgreen
cal · 1998 · cited in 1 California opinions naming this issue, 2021–2021
2 sentences

2021(People v. Venegas (1998) 18 Cal.4th 47, 88 [relying in part on state court decisions using the Daubert standard]; People v. Buell (2017) 16 Cal.App.5th 682 , 690–691 [same].) 28 relied on the database never claimed that the database positively identified the defendant’s print.

2021(People v. Venegas (1998) 18 Cal.4th 47, 88 [relying in part on state court decisions using the Daubert standard]; People v. Buell (2017) 16 Cal.App.5th 682 , 690–691 [same].) 28 relied on the database never claimed that the database positively identified the defendant’s print.

11
People v. Lucasgreen
cal · 2014 · cited in 1 California opinions naming this issue, 2021–2021
2 sentences

2021(Lucas, supra, 60 Cal.4th at p. 245, fn. 36 .) We reject the claim of error.

2021But we have previously rejected such claims, and defendant offers no persuasive reason for reconsideration of our conclusion. [Citation.] In addition, our opinion in [Sargon], did not, by using the term ‘gatekeeper,’ indicate any move away from the Kelly test toward the federal Daubert standard.” (Lucas, supra, 60 Cal.4th at p. 245, fn. 36 .) Likewise, in the present case, defendant’s Sargon argument amounts to an invitation to abandon the Kelly test in favor of the federal Daubert standard.

11
People v. Morrisgreen
cal · 1991 · cited in 1 California opinions naming this issue, 2014–2014
1 sentence

2014(Sargon Enterprises, Inc. v. University of Southern California, supra, 55 Cal.4th at p. 772, fn. 6 .) 37 “Electrophoresis allows typing of individual blood proteins and enzymes found in a blood sample by a method that separates electrically charged molecules.” (People v. Morris, supra, 53 Cal.3d at p. 206.) 38 In Crawford , Washington state law forbid the defendant’s spouse from testifying without the defendant husband’s consent, which he refused to give.

11
State v. Cody Clarkgreen
mont · 2008 · cited in 1 California opinions naming this issue, 2013–2013
2 sentences

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

11
State v. Stankgreen
wisctapp · 2005 · cited in 1 California opinions naming this issue, 2013–2013
2 sentences

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

11
Rock v. Arkansasgreen
scotus · 1987 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

11
cluster 732510green
ca9 · 1997 · cited in 1 California opinions naming this issue, 2004–2004
11
People v. Keglergreen
calctapp · 1987 · cited in 1 California opinions naming this issue, 2004–2004
11
United States v. Crumbygreen
azd · 1995 · cited in 1 California opinions naming this issue, 2004–2004
11
United States v. Scheffergreen
scotus · 1998 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

11
United States v. Julio Piccinonnagreen
ca11 · 1989 · cited in 1 California opinions naming this issue, 2004–2004
11
People v. Aontae D.green
calctapp · 1994 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

11
Chambers v. Mississippigreen
scotus · 1973 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

11
United States v. Galbrethgreen
nmd · 1995 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

11
Green v. Georgiagreen
scotus · 1979 · cited in 1 California opinions naming this issue, 2004–2004
2 sentences

2004In Rock , the United States Supreme Court concluded that a per se rule excluding all hypnotically refreshed testimony infringed upon the defendant's constitutional right to testify, where the rule prevented the defendant from testifying regarding the circumstances underlying the charged killing, including whether it was accidental. ( Rock v. Arkansas, supra, 483 U.S. at pp. 56-62, 107 S.Ct. 2704 .) The court in Chambers held that the defendant's constitutional right to present a defense was impaired by Mississippi's "voucher" rule, which prevented the defendant from impeaching a defense witnes

2004In Rock , the United States Supreme Court concluded that a per se rule excluding all hypnotically refreshed testimony infringed upon the defendant's constitutional right to testify, where the rule prevented the defendant from testifying regarding the circumstances underlying the charged killing, including whether it was accidental. ( Rock v. Arkansas, supra, 483 U.S. at pp. 56-62, 107 S.Ct. 2704 .) The court in Chambers held that the defendant's constitutional right to present a defense was impaired by Mississippi's "voucher" rule, which prevented the defendant from impeaching a defense witnes

11
Isely v. Capuchin Provincegreen
mied · 1995 · cited in 1 California opinions naming this issue, 1999–1999
11
K.B. v. Evangelical Lutheran Church in Americagreen
minnctapp · 1995 · cited in 1 California opinions naming this issue, 1999–1999
11
Shahzade v. Gregorygreen
mad · 1996 · cited in 1 California opinions naming this issue, 1999–1999
11
State v. Copelandgreen
wash · 1996 · cited in 1 California opinions naming this issue, 1999–1999
11
Emerson v. Stategreen
texcrimapp · 1994 · cited in 1 California opinions naming this issue, 1995–1995
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in California. Read the followed side critically anyway.

Also cited on this issue (30)

CaseCitedYears
Daubert v. Merrell Dow Pharmaceuticals, Inc. green
scotus · 1993
2 sentences

2022(See Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) 509 U.S. 579, 586 ; Soto, supra, 21 Cal.4th at p. 515, fn. 3.) “Though the federal Daubert standard for admission of scientific evidence differs somewhat from the Kelly standard, appellate decisions affirming the admission of scientific evidence under that standard are relevant to the Kelly analysis.” (People v. Lund (2021) 64 Cal.App.5th 1119 , 1140, fn. 6 (Lund).) 10 Nevertheless, “proof of a technique’s general acceptance in the relevant scientific community [is not] necessary once a published appellate decision ha[s] affirmed a trial

2004(See United States v. Cordoba (9th Cir.1997) 104 F.3d 225, 227-229 [holding that the Ninth Circuit's per se ban on polygraph evidence, based upon Frye , was overturned by Daubert v. Merrell Dow Pharmaceuticals, Inc., supra, 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 , which concluded the Federal Rules of Evidence superceded the Frye "general acceptance" test in federal courts]; United States v. Piccinonna (11th Cir.1989) 885 F.2d 1529, 1532-1537 [concluding there was no per se ban on polygraph evidence in the Eleventh Circuit]; United States v. Galbreth, supra, 908 F.Supp. 877, 890-896 [h

61998–2022
In Re Zurn Pex Plumbing Products Liability green
ca8 · 2011
2 sentences

2018(See, e.g., In re Zurn Pex Plumbing Products Liability Litigation (8th Cir. 2011) 644 F.3d 604 , 614 ; Fosmire v. Progressive Max Insurance Co. (W.D.Wash. 2011) 277 F.R.D. 625 , 629.) The fact that federal courts apply their Daubert standard at class certification shows both the feasibility and desirability of ensuring the reliability of expert opinion evidence at this stage.

2018(See, e.g., In re Zurn Pex Plumbing Products Liability Litigation (8th Cir. 2011) 644 F.3d 604, 614 ; Fosmire v. Progressive Max Insurance Co. (W.D.Wash. 2011) 277 F.R.D. 625, 629 .) The fact that federal courts apply their Daubert standard at class certification shows both the feasibility and desirability of ensuring the reliability of expert opinion evidence at this stage.

22018–2018
Fosmire v. Progressive Max Insurance green
wawd · 2011
2 sentences

2018(See, e.g., In re Zurn Pex Plumbing Products Liability Litigation (8th Cir. 2011) 644 F.3d 604 , 614 ; Fosmire v. Progressive Max Insurance Co. (W.D.Wash. 2011) 277 F.R.D. 625 , 629.) The fact that federal courts apply their Daubert standard at class certification shows both the feasibility and desirability of ensuring the reliability of expert opinion evidence at this stage.

2018(See, e.g., In re Zurn Pex Plumbing Products Liability Litigation (8th Cir. 2011) 644 F.3d 604, 614 ; Fosmire v. Progressive Max Insurance Co. (W.D.Wash. 2011) 277 F.R.D. 625, 629 .) The fact that federal courts apply their Daubert standard at class certification shows both the feasibility and desirability of ensuring the reliability of expert opinion evidence at this stage.

22018–2018
Stone v. Advance America green
casd · 2011
2 sentences

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970 , 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164 , 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562 , 566.) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or *1120 "focused" Daubert analysis, the substantive result appears the same.

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970, 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164, 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562, 566 .) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or "focused" Daubert analysis, the substantive result appears the same.

22018–2018
Kamakahi v. American Society for Reproductive Medicine green
cand · 2015
2 sentences

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970 , 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164 , 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562 , 566.) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or *1120 "focused" Daubert analysis, the substantive result appears the same.

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970, 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164, 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562, 566 .) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or "focused" Daubert analysis, the substantive result appears the same.

22018–2018
Ellis v. Costco Wholesale Corp. green
ca9 · 2011
2 sentences

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970 , 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164 , 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562 , 566.) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or *1120 "focused" Daubert analysis, the substantive result appears the same.

2018(See, e.g., Ellis v. Costco Wholesale Corp. (9th Cir. 2011) 657 F.3d 970, 982 ; Kamakahi v. American Society for Reproductive Medicine (N.D.Cal. 2015) 305 F.R.D. 164, 176 ; Stone v. Advance America (S.D.Cal. 2011) 278 F.R.D. 562, 566 .) Although some federal courts appear to have a largely semantic disagreement over whether to apply a "full" or "focused" Daubert analysis, the substantive result appears the same.

22018–2018
People v. Kelly red
cal · 1976
2 sentences

2018(Kelly, supra, 17 Cal.3d at p. 30 .) The Kelly/Daubert rule applies only to expert testimony “based, in whole or part, on a technique, process, or theory which is new to science, and, even more so, the law.” (People v. Stoll (1989) 49 Cal.3d 1136, 1156 .) The Kelly/Daubert rule applies only if “the unproven technique or procedure appears in both name and description to provide some definitive truth which the expert need only accurately recognize and relay to the jury.

2011First, California has rejected the Daubert analysis in favor of the test in Kelly, supra, 17 Cal.3d 24 .

22011–2018
State v. Anderson green
nm · 1994
2 sentences

1999(See, e.g., Com. v. Blasioli (1998) 552 Pa. 149 [ 713 A.2d 1117 ] [Pennsylvania; Frye test]; State v. Freeman (1997) 253 Neb. 385 [ 571 N.W.2d 276 ] [Nebraska; Frye test]; Armstead v. State, supra, 673 A.2d 221 [Maryland; Frye test and statute authorizing admissibility of RFLP statistical evidence]; State v. Copeland, supra, 922 P.2d 1304 [Washington; Frye test]; People v. Miller (1996) 173 Ill.2d 167 [219 Ill.Dec 43, 670 N.E.2d 721 ] [Illinois; Frye test]; State v. Marcus (1996) 294 N.J.Super. 267 [ 683 A.2d 221 ] [New Jersey; Frye test]; State v. Morel (R.I. 1996) 676 A.2d 1347 [Rhode Island

1999(See, e.g., Com. v. Blasioli (1998) 552 Pa. 149 [ 713 A.2d 1117 ] [Pennsylvania; Frye test]; State v. Freeman (1997) 253 Neb. 385 [ 571 N.W.2d 276 ] [Nebraska; Frye test]; Armstead v. State, supra, 673 A.2d 221 [Maryland; Frye test and statute authorizing admissibility of RFLP statistical evidence]; State v. Copeland, supra, 922 P.2d 1304 [Washington; Frye test]; People v. Miller (1996) 173 Ill.2d 167 [219 Ill.Dec 43, 670 N.E.2d 721 ] [Illinois; Frye test]; State v. Marcus (1996) 294 N.J.Super. 267 [ 683 A.2d 221 ] [New Jersey; Frye test]; State v. Morel (R.I. 1996) 676 A.2d 1347 [Rhode Island

21998–1999
Auto Equity Sales, Inc. v. Superior Court green
cal · 1962
1 sentence

2021(Auto Equity Sales, Inc. v. Superior Court (1962) 57 Cal.2d 450, 455 .) The trial court surveyed a wide range of scientific perspectives and reasonably found that firearms comparison evidence continues to be generally accepted in the relevant scientific community.9 The trial court had no obligation under Sargon to independently evaluate the reliability of firearms comparison evidence under the federal Daubert standard.

12021–2021
People v. Buell green
calctapp5d · 2017
2 sentences

2021(People v. Venegas (1998) 18 Cal.4th 47, 88 [relying in part on state court decisions using the Daubert standard]; People v. Buell (2017) 16 Cal.App.5th 682 , 690–691 [same].) 28 relied on the database never claimed that the database positively identified the defendant’s print.

2021(People v. Venegas (1998) 18 Cal.4th 47, 88 [relying in part on state court decisions using the Daubert standard]; People v. Buell (2017) 16 Cal.App.5th 682 , 690–691 [same].) 28 relied on the database never claimed that the database positively identified the defendant’s print.

12021–2021
United States v. Baines green
ca10 · 2009
2 sentences

2018(Cf. U.S. v. Baines (10th Cir. 2009) 573 F.3d 979 , 988 [upholding the admission of fingerprint evidence under the Daubert standard and noting, inter alia: "Every published decision to address this issue has found the evidence admissible.

2018(Cf. U.S. v. Baines (10th Cir. 2009) 573 F.3d 979 , 988 [upholding the admission of fingerprint evidence under the Daubert standard and noting, inter alia: "Every published decision to address this issue has found the evidence admissible.

12018–2018
People v. Harlan green
calctapp · 1990
2 sentences

2018In People v. Harlan (1990) 222 Cal.App.3d 439, 448-450 , the Court of Appeal concluded that CSAAS is not scientific evidence subject to the Kelly/Daubert rule.

2018In People v. Harlan (1990) 222 Cal.App.3d 439, 448-450 , the Court of Appeal concluded that CSAAS is not scientific evidence subject to the Kelly/Daubert rule.

12018–2018
People v. Stoll green
cal · 1989
1 sentence

2018(Kelly, supra, 17 Cal.3d at p. 30 .) The Kelly/Daubert rule applies only to expert testimony “based, in whole or part, on a technique, process, or theory which is new to science, and, even more so, the law.” (People v. Stoll (1989) 49 Cal.3d 1136, 1156 .) The Kelly/Daubert rule applies only if “the unproven technique or procedure appears in both name and description to provide some definitive truth which the expert need only accurately recognize and relay to the jury.

12018–2018
People v. Shirley green
cal · 1982
1 sentence

2018(People v. Shirley (1982) 31 Cal.3d 18, 34 .) Reliability of the evidence is established by showing that the method has gained general acceptance in the relevant scientific community.

12018–2018
People v. Carmony green
cal · 2004
2 sentences

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

12013–2013
People v. Palaschak green
cal · 1995
2 sentences

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

2013(Palaschak, supra, 9 Cal.4th at p. 1242 .) 10 court’s decision to admit the testimony was not “‘so irrational or arbitrary that no reasonable person could agree with it.’” (Sargon, supra, 55 Cal.4th at p. 773 , quoting People v. Carmony (2004) 33 Cal.4th 367, 377 ; see also State v. Clark (Mont. 2008) 198 P.3d 809, 819 [pharmacist’s “testimony regarding the identification of prescription drugs by reference to their unique imprint code and national pharmaceutical databases is not novel scientific evidence requiring a Daubert hearing”]; Stank, supra, 708 N.W.2d at p. 55 [noting courts “have reco

12013–2013
State v. Morel green
ri · 1996
11999–1999
State v. Weeks green
mont · 1995
11999–1999
State v. Dinkins green
sc · 1995
11999–1999
Armstead v. State green
md · 1996
11999–1999
State v. Futrell green
ncctapp · 1993
11999–1999
Lindsey v. People green
colo · 1995
11999–1999
Commonwealth v. Blasioli green
pa · 1998
11999–1999
State v. Marcus green
njsuperctappdiv · 1996
11999–1999
People v. Miller green
ill · 1996
11999–1999
People v. Chandler green
michctapp · 1995
11999–1999
Taylor v. State green
oklacrimapp · 1995
11999–1999
State v. Freeman green
neb · 1997
11999–1999
State v. Streich green
vt · 1995
11998–1998
State v. Hungerford green
nh · 1997
11997–1997

Statutes the citing opinions construe

CA § Cal. Evidence Code § 801 (5) CA § Cal. Penal Code § 187 (5) CA § Cal. Evidence Code § 210 (4) CA § Cal. Evidence Code § 352 (4) CA § Cal. Evidence Code § 353 (3) CA § Cal. Evidence Code § 720 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

TX 149 (1996–2026) LA 145 (1994–2026) MS 126 (1996–2026) OH 102 (1998–2026) MI 82 (2004–2026) KY 81 (1995–2026) DE 59 (2000–2026) WI 55 (2013–2026) FL 48 (2001–2026) GA 42 (2004–2026) CT 39 (1997–2025) OK 38 (1994–2026) NE 35 (1994–2024) MD 35 (2000–2026) SD 34 (1996–2026) AZ 31 (1995–2026) NC 30 (2000–2025) NM 30 (1994–2022) AL 27 (1998–2025) MA 27 (1996–2025) KS 27 (1995–2026) NJ 24 (2000–2026) PA 24 (1997–2022) WY 23 (1999–2025) VT 23 (2000–2026) AK 23 (1999–2025) IN 21 (1995–2023) MT 20 (1994–2026) NY 18 (1997–2017) NH 18 (1994–2025) CA 18 (1995–2023) MO 18 (1995–2025) IL 17 (1998–2025) AR 17 (2003–2025) WV 14 (1995–2024) WA 13 (1994–2025) IA 12 (1997–2026) DC 10 (2011–2026) RI 9 (1999–2024) OR 6 (1996–2025) ID 6 (2002–2022) CO 6 (1999–2021) HI 6 (1997–2020) VI 6 (2001–2017) SC 6 (2000–2025) UT 5 (1996–2012) TN 5 (2002–2020) MN 5 (2000–2019) NV 3 (1998–2014) ME 2 (2003–2005) VA 2 (2004–2006) GU 2 (2021–2022)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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