Daubert factors (Missouri) · Go Syfert
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Daubert factors in Missouri

18 Missouri opinions name it 2 courts 1995–2025 4 in the last five years

The cases below were cited by Missouri 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 (11)

CaseFollowedCited
Daubert v. Merrell Dow Pharmaceuticals, Inc.green
scotus · 1993 · cited in 9 Missouri opinions naming this issue, 2018–2025
2 sentences

2025Her testimony in Defendant’s case “would be offered to give general testimony of behaviors and character[istic]s commonly found in those who have been the victims of domestic 1 The Daubert standard is a reference to Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), which applies to federal cases.

2025Her testimony in Defendant’s case “would be offered to give general testimony of behaviors and character[istic]s commonly found in those who have been the victims of domestic 1 The Daubert standard is a reference to Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 (1993), which applies to federal cases.

49
Bonnie Joyce Rider v. Sandoz Pharmaceuticalsgreen
ca11 · 2002 · cited in 2 Missouri opinions naming this issue, 2020–2020
2 sentences

2020Corp., 295 F.3d 1194, 1198 (11th Cir. 2002) (noting that the lack of epidemiological studies on the nexus between external factors and disease is not fatal to a plaintiff’s toxic tort action); Kennedy v. Collagen 14 Corp., 161 F.3d 1226, 1229 (9th Cir. 1998) (internal citation omitted) (noting courts’ recognition that the Daubert standard does not require expert testimony to be based on epidemiological data or identical case studies to prove causation).

2020Corp., 295 F.3d 1194, 1198 (11th Cir. 2002) (noting that the lack of epidemiological studies on the nexus between external factors and disease is not fatal to a plaintiff’s toxic tort action); Kennedy v. Collagen 14 Corp., 161 F.3d 1226, 1229 (9th Cir. 1998) (internal citation omitted) (noting courts’ recognition that the Daubert standard does not require expert testimony to be based on epidemiological data or identical case studies to prove causation).

22
Charlotte KENNEDY and Robert Kennedy, Plaintiffs-Appellants, v. COLLAGEN CORPORATION, Defendant-Appelleegreen
ca9 · 1998 · cited in 2 Missouri opinions naming this issue, 2020–2020
2 sentences

2020Corp., 295 F.3d 1194, 1198 (11th Cir. 2002) (noting that the lack of epidemiological studies on the nexus between external factors and disease is not fatal to a plaintiff’s toxic tort action); Kennedy v. Collagen 14 Corp., 161 F.3d 1226, 1229 (9th Cir. 1998) (internal citation omitted) (noting courts’ recognition that the Daubert standard does not require expert testimony to be based on epidemiological data or identical case studies to prove causation).

2020Corp., 295 F.3d 1194, 1198 (11th Cir. 2002) (noting that the lack of epidemiological studies on the nexus between external factors and disease is not fatal to a plaintiff’s toxic tort action); Kennedy v. Collagen 14 Corp., 161 F.3d 1226, 1229 (9th Cir. 1998) (internal citation omitted) (noting courts’ recognition that the Daubert standard does not require expert testimony to be based on epidemiological data or identical case studies to prove causation).

22
Cheatum v. Stategreen
moctapp · 2019 · cited in 2 Missouri opinions naming this issue, 2020–2021
2 sentences

2021See State v. Boss, 577 S.W.3d 509, 518-19 (Mo. App. W.D. 2019) (holding toolmark examination evidence was sufficiently reliable, even if results somewhat rely on a “subjective analysis” and the examiner’s expertise and experience).

2021See State v. Boss, 577 S.W.3d 509, 518-19 (Mo. App. W.D. 2019) (holding toolmark examination evidence was sufficiently reliable, even if results somewhat rely on a “subjective analysis” and the examiner’s expertise and experience).

12
Michael Ray Thomas v. Harley-Davidson Motor Company Group, LLCgreen
moctapp · 2019 · cited in 1 Missouri opinions naming this issue, 2021–2021
2 sentences

2021See Thomas v. Harley-Davidson Motor Co. Grp., LLC, 571 S.W.3d 126, 137 (Mo. App. W.D. 2019) (“Missouri appellate courts have long been reluctant to convict a trial court of error when the complaining party did not seek relief from the trial court[.]”). 6 v. Follwell, 554 S.W.3d 878, 881 (Mo. banc 2018) (quoting Lozano v. BNSF Ry.

2021See Thomas v. Harley-Davidson Motor Co. Grp., LLC, 571 S.W.3d 126, 137 (Mo. App. W.D. 2019) (“Missouri appellate courts have long been reluctant to convict a trial court of error when the complaining party did not seek relief from the trial court[.]”). 6 v. Follwell, 554 S.W.3d 878, 881 (Mo. banc 2018) (quoting Lozano v. BNSF Ry.

11
Shallow v. Follwellgreen
mo · 2018 · cited in 1 Missouri opinions naming this issue, 2021–2021
2 sentences

2021See Thomas v. Harley-Davidson Motor Co. Grp., LLC, 571 S.W.3d 126, 137 (Mo. App. W.D. 2019) (“Missouri appellate courts have long been reluctant to convict a trial court of error when the complaining party did not seek relief from the trial court[.]”). 6 v. Follwell, 554 S.W.3d 878, 881 (Mo. banc 2018) (quoting Lozano v. BNSF Ry.

2021See Thomas v. Harley-Davidson Motor Co. Grp., LLC, 571 S.W.3d 126, 137 (Mo. App. W.D. 2019) (“Missouri appellate courts have long been reluctant to convict a trial court of error when the complaining party did not seek relief from the trial court[.]”). 6 v. Follwell, 554 S.W.3d 878, 881 (Mo. banc 2018) (quoting Lozano v. BNSF Ry.

11
Reynolds v. Stategreen
texapp · 2007 · cited in 1 Missouri opinions naming this issue, 2020–2020
2 sentences

2020Similarly, the Texas Court of Appeals held that the reliability of similar testimony of a licensed professional counselor and trained forensic interviewer should be evaluated by asking if “(1) the field of expertise is a legitimate one, (2) the subject matter of the expert's testimony is within the scope of that field, and (3) the expert's testimony properly relies on and/or utilizes the principles involved in the field.” Reynolds v. State, 227 S.W.3d 355, 371 (Tex. App. 2007) (citations omitted).2 In Suttles, the Eastern District concluded that expert testimony concerning delayed disclosures

2020Similarly, the Texas Court of Appeals held that the reliability of similar testimony of a licensed professional counselor and trained forensic interviewer should be evaluated by asking if “(1) the field of expertise is a legitimate one, (2) the subject matter of the expert's testimony is within the scope of that field, and (3) the expert's testimony properly relies on and/or utilizes the principles involved in the field.” Reynolds v. State, 227 S.W.3d 355, 371 (Tex. App. 2007) (citations omitted).2 In Suttles, the Eastern District concluded that expert testimony concerning delayed disclosures

11
State v. J.L.G.green
nj · 2018 · cited in 1 Missouri opinions naming this issue, 2019–2019
2 sentences

2019Id. at 464 .5 Although the delayed-disclosures theory is not easily subject to peer review and/or publication under the Daubert factors, scientists generally accept the theory to explain a common behavior seen in child-victims of sexual abuse.

2019Id. at 464 .5 Although the delayed-disclosures theory is not easily subject to peer review and/or publication under the Daubert factors, scientists generally accept the theory to explain a common behavior seen in child-victims of sexual abuse.

11
Frye v. United Statesred
cadc · 1923 · cited in 1 Missouri opinions naming this issue, 2019–2019
2 sentences

2019Prior to 2017, Section 490.065 applied a standard for the admissibility of expert testimony similar to that found in Frye v. United States, 293 F. 1013, 1014 (D.C.

2019Prior to 2017, Section 490.065 applied a standard for the admissibility of expert testimony similar to that found in Frye v. United States, 293 F. 1013, 1014 (D.C.

11
United States v. Rosegreen
mdd · 2009 · cited in 1 Missouri opinions naming this issue, 2017–2017
2 sentences

2017United States v. Rose, 672 F.Supp.2d 723, 725 (2009) (Holding under the Daubert standard "[i]t appears that every federal circuit to consider the issue has found expert fingerprint identification testimony admissible [.] ”). .

2017United States v. Rose, 672 F.Supp.2d 723, 725 (2009) (Holding under the Daubert standard "[i]t appears that every federal circuit to consider the issue has found expert fingerprint identification testimony admissible [.] ”). .

11
Keyser v. Keysergreen
moctapp · 2002 · cited in 1 Missouri opinions naming this issue, 2003–2003
2 sentences

2003W.D. 2002) ("whether [section] 490.065 supersedes the Frye doctrine ... has not yet been decided by our Supreme Court” and "no Missouri case has yet decided what, if any, impact adoption of [section] 490.065 has on the application of the Frye 'general acceptance' rule, much less whether it compels application of the Daubert standard,” citing section 490.065 for the admissibility of expert testimony, and stating that Frye is the proper standard for analyzing the admissibility of expert testimony related to scientific techniques); Keyser v. Keyser, 81 S.W.3d 164, 169 (Mo.App.

2003W.D. 2002) ("whether [section] 490.065 supersedes the Frye doctrine ... has not yet been decided by our Supreme Court” and "no Missouri case has yet decided what, if any, impact adoption of [section] 490.065 has on the application of the Frye 'general acceptance' rule, much less whether it compels application of the Daubert standard,” citing section 490.065 for the admissibility of expert testimony, and stating that Frye is the proper standard for analyzing the admissibility of expert testimony related to scientific techniques); Keyser v. Keyser, 81 S.W.3d 164, 169 (Mo.App.

11

Distinguished, questioned or overruled (2)

CaseNegativeCited
State v. Rittgreen
minn · 1999 · cited in 1 Missouri opinions naming this issue, 2000–2000
2 sentences

2000But see State v. Ritt, 599 N.W.2d 802 (Minn.1999) excluding such testimony under the Frye test and State v. Tetlier, 526 A.2d 941 (Me.1987) excluding such testimony under Daubert.

2000But see State v. Ritt, 599 N.W.2d 802 (Minn.1999) excluding such testimony under the Frye test and State v. Tetlier, 526 A.2d 941 (Me.1987) excluding such testimony under Daubert.

11
State v. Telliergreen
me · 1987 · cited in 1 Missouri opinions naming this issue, 2000–2000
2 sentences

2000But see State v. Ritt, 599 N.W.2d 802 (Minn.1999) excluding such testimony under the Frye test and State v. Tetlier, 526 A.2d 941 (Me.1987) excluding such testimony under Daubert.

2000But see State v. Ritt, 599 N.W.2d 802 (Minn.1999) excluding such testimony under the Frye test and State v. Tetlier, 526 A.2d 941 (Me.1987) excluding such testimony under Daubert.

11

Also cited on this issue (5)

CaseCitedYears
State v. Wright green
moctapp · 2018
2 sentences

2019The Wright court noted, however, that: [Federal Rules of Evidence Rule 702] does not codify the Daubert factors, but is "broad enough to require consideration of any or all of the specific Daubert factors where appropriate." Other factors may also be relevant, but "no single factor is necessarily dispositive of the reliability of a particular expert’s testimony." Thus, while the rule enumerates some considerations, the inquiry about admissibility is still intended to be flexible. 13 Id. at 318-19 (citing Advisory Committee Notes, Fed.

2019The Wright court noted, however, that: [Federal Rules of Evidence Rule 702] does not codify the Daubert factors, but is "broad enough to require consideration of any or all of the specific Daubert factors where appropriate." Other factors may also be relevant, but "no single factor is necessarily dispositive of the reliability of a particular expert’s testimony." Thus, while the rule enumerates some considerations, the inquiry about admissibility is still intended to be flexible. 13 Id. at 318-19 (citing Advisory Committee Notes, Fed.

32019–2020
Kumho Tire Co. v. Carmichael green
scotus · 1999
2 sentences

2018The amended rule does not codify the Daubert factors, but is "broad enough to require consideration of any or all of the specific Daubert factors where appropriate." Id.

2018The amended rule does not codify the Daubert factors, but is "broad enough to require consideration of any or all of the specific Daubert factors where appropriate." Id.

22018–2019
Oliphant v. Ries green
ky · 2015
1 sentence

2019Oliphant v. Ries, 460 S.W.3d 889 (Ky. 2015).

12019–2019
United States v. Larry D. Hall green
ca7 · 1996
2 sentences

2000In Unites States v. Hall, the Seventh Circuit allowed expert testimony on coercive police interrogation and the incidence of false confessions under the Daubert standard. 93 F.3d 1337 (7th Cir.1996).

2000In Unites States v. Hall, the Seventh Circuit allowed expert testimony on coercive police interrogation and the incidence of false confessions under the Daubert standard. 93 F.3d 1337 (7th Cir.1996).

12000–2000
Sherrod v. Berry green
ca7 · 1987
2 sentences

1995Schumann cites Sherrod v. Berry, 827 F.2d 195 (7th Cir. 1987), as a case where expert testimony on he-donic damages was approved.

1995Schumann cites Sherrod v. Berry, 827 F.2d 195 (7th Cir. 1987), as a case where expert testimony on he-donic damages was approved.

11995–1995

Statutes the citing opinions construe

MO § Mo. Rev. Stat. § 490.065 (15) MO § Mo. Rev. Stat. § 571.015 (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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