scientific principle (New Mexico) · Go Syfert
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scientific principle in New Mexico

18 New Mexico opinions name it 2 courts 1966–2025 1 in the last five years

The cases below were cited by New Mexico 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 (10)

CaseFollowedCited
Frye v. United Statesred
cadc · 1923 · cited in 5 New Mexico opinions naming this issue, 1974–1994
2 sentences

1994The concept of examining the “general acceptance” of a particular scientific theory and procedure stems from Frye, in which the D.C.Circuit held: While courts will go a long way in admitting expert testimony deduced from a well-recognized scientific principle or discovery, the thing from which the deduction is made must be sufficiently established to have gained general acceptance in the particular field in which it belongs. 293 F. at 1014 .

1993Frye v. United States, 293 F. 1013, 1014 (D.C.Cir.1923) (emphasis added). .

35
Melendez-Diaz v. Massachusettsgreen
scotus · 2009 · cited in 2 New Mexico opinions naming this issue, 2012–2012
2 sentences

2012Id. at___,___, 129 S. Ct. at 2533, 2537 (explaining that cross-examination under oath in open court may cause “the analyst who provides false results . . . [to] reconsider his false testimony”). {24} Similarly, in Bullcoming, the United States Supreme Court again focused on the necessity of cross-examination of a person “with a personal, albeit limited, connection to the scientific test at issue.” 564 U.S. at___, 131 S. Ct. at 2722 (Sotomayor, J., concurring in part).

2012Id. at___,___, 129 S. Ct. at 2533, 2537 (explaining that cross-examination under oath in open court may cause “the analyst who provides false results . . . [to] reconsider his false testimony”). {24} Similarly, in Bullcoming, the United States Supreme Court again focused on the necessity of cross-examination of a person “with a personal, albeit limited, connection to the scientific test at issue.” 564 U.S. at___, 131 S. Ct. at 2722 (Sotomayor, J., concurring in part).

22
Bullcoming v. New Mexicogreen
scotus · 2011 · cited in 2 New Mexico opinions naming this issue, 2012–2012
2 sentences

2012Id. at___,___, 129 S. Ct. at 2533, 2537 (explaining that cross-examination under oath in open court may cause “the analyst who provides false results . . . [to] reconsider his false testimony”). {24} Similarly, in Bullcoming, the United States Supreme Court again focused on the necessity of cross-examination of a person “with a personal, albeit limited, connection to the scientific test at issue.” 564 U.S. at___, 131 S. Ct. at 2722 (Sotomayor, J., concurring in part).

2012Id. at ___, ___, 129 S. Ct. at 2533, 2537 (explaining that cross-examination under oath in open court may cause “the analyst who provides false results . . . [to] reconsider his false testimony”). {24} Similarly, in Bullcoming, the United States Supreme Court again focused on the necessity of cross-examination of a person “with a personal, albeit limited, connection to the scientific test at issue.” 564 U.S. at ___ , 131 S. Ct. at 2722 (Sotomayor, J., concurring in part).

22
State v. Martingreen
nm · 1984 · cited in 2 New Mexico opinions naming this issue, 1993–1993
2 sentences

1993“The court must merely determine whether the scientific procedure which supports the testimony is ‘based on a well-recognized scientific principle or discovery and whether it is capable of supporting opinions based upon a reasonable probability rather than conjecture.’ ” State v. Martin, 101 N.M. 595, 606 , 686 P.2d 937, 948 (1984) (quoting Blea, 101 N.M. at 326 , 681 P.2d at 1103 ).

1993“The court must merely determine whether the scientific procedure which supports the testimony is ‘based on a well-recognized scientific principle or discovery and whether it is capable of supporting opinions based upon a reasonable probability rather than conjecture.’ ” State v. Martin, 101 N.M. 595, 606 , 686 P.2d 937, 948 (1984) (quoting Blea, 101 N.M. at 326 , 681 P.2d at 1103 ).

22
State v. Bleagreen
nm · 1984 · cited in 4 New Mexico opinions naming this issue, 1984–1993
2 sentences

1993Our Supreme Court has stated that in order for a scientific principle to be accepted as reliable, it must be “well-recognized.” Blea, 101 N.M. at 326 , 681 P.2d at 1103 .

1993Our Supreme Court has stated that in order for a scientific principle to be accepted as reliable, it must be “well-recognized.” Blea, 101 N.M. at 326 , 681 P.2d at 1103 .

14
State v. Moralesgreen
nmctapp · 2002 · cited in 1 New Mexico opinions naming this issue, 2018–2018
1 sentence

2018See Morales, 2002-NMCA-052, ¶ 7 ; see also NMSA 1978, § 30-31-2(E) 6 (2009) (defining a “controlled substance” as a particular substance listed in Schedules 7 I through V of the Controlled Substances Act, NMSA 1978, §§ 30-31-6 to -10 (2005, 8 as amended through 2011), or rules adopted in accord with those statutes). 9 CONCLUSION 10 {11} For the foregoing reasons, we affirm the district court’s evidentiary ruling. 11 {12} IT IS SO ORDERED. 12 ______________________________ 13 EMIL J.

11
State v. Lindemuthgreen
nm · 1952 · cited in 1 New Mexico opinions naming this issue, 1994–1994
2 sentences

1994The Frye test was first adopted in New Mexico in 1952 when this Court affirmed a district court’s exclusion of expert opinion testimony regarding truth serum that was not “reliable or generally approved and accepted by members of the medical profession specializing in psychiatry.” State v. Lindemuth, 56 N.M. 257, 271 , 243 P.2d 325, 334 (1952).

1994The Frye test was first adopted in New Mexico in 1952 when this Court affirmed a district court’s exclusion of expert opinion testimony regarding truth serum that was not “reliable or generally approved and accepted by members of the medical profession specializing in psychiatry.” State v. Lindemuth, 56 N.M. 257, 271 , 243 P.2d 325, 334 (1952).

11
Simon Neustadt Family Center, Inc. v. Bludworthgreen
nmctapp · 1982 · cited in 1 New Mexico opinions naming this issue, 1993–1993
2 sentences

1993This is because “[a]t some point, a new scientific technique becomes reliable enough to be used in court.” Simon Neustadt Family Ctr., Inc. v. Bludworth, 97 N.M. 500, 504 , 641 P.2d 531, 535 (Ct.App. 1982), overruled on other grounds, Melnick v. State Farm Mut.

1993This is because “[a]t some point, a new scientific technique becomes reliable enough to be used in court.” Simon Neustadt Family Ctr., Inc. v. Bludworth, 97 N.M. 500, 504 , 641 P.2d 531, 535 (Ct.App. 1982), overruled on other grounds, Melnick v. State Farm Mut.

11
United States v. Yeegreen
ohnd · 1991 · cited in 1 New Mexico opinions naming this issue, 1993–1993
1 sentence

1993See Yee, 134 F.R.D. at 196 .

11
State v. Dorseygreen
nm · 1975 · cited in 1 New Mexico opinions naming this issue, 1984–1984
2 sentences

1984See State v. Dorsey, 88 N.M. 184 , 539 P.2d 204 (1975); State v. Beachum, 97 N.M. 682 , 643 P.2d 246 (Ct.App.1981), cert. quashed, 98 N.M. 51 , 644 P.2d 1040 (1982); accord Frye v. United States, 293 F. 1013 (D.C.Cir.1923).

1984See State v. Dorsey, 88 N.M. 184 , 539 P.2d 204 (1975); State v. Beachum, 97 N.M. 682 , 643 P.2d 246 (Ct.App.1981), cert. quashed, 98 N.M. 51 , 644 P.2d 1040 (1982); accord Frye v. United States, 293 F. 1013 (D.C.Cir.1923).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Lee v. Martinez green
nm · 2004
2 sentences

2016In Lee v. Martinez, our Supreme Court reviewed the accuracy rates of polygraph results, noting that, while “far from conclusive[,] . . . numerous studies have shown that polygraph tests can detect deception at rates well above chance.” 2004-NMSC- 027, ¶ 32, 136 N.M. 166 , 96 P.3d 291 .

2016In Lee v. Martinez, our Supreme Court reviewed the accuracy rates of polygraph results, noting that, while “far from conclusive[,] . . . numerous studies have shown that polygraph tests can detect deception at rates well above chance.” 2004-NMSC- 027, ¶ 32, 136 N.M. 166 , 96 P.3d 291 .

22016–2016
State v. Beachum green
nmctapp · 1982
2 sentences

1986State v. Beachum, 97 N.M. 682 , 643 P.2d 246 (Ct.App.1981).

1986State v. Beachum, 97 N.M. 682 , 643 P.2d 246 (Ct.App.1981).

21984–1986
State v. Martinez green
nm · 2007
2 sentences

2025Cf. State v. Martinez, 2007-NMSC-025, ¶ 9 , 141 N.M. 713 , 160 P.3d 894 (internal quotation marks and citation omitted); see also State v. Espinoza, 2023-NMCA-012 , ¶¶ 12-13, 525 P.3d 429 (distinguishing between the foundational evidence that supports the result of a scientific test and the result itself).

2025Cf. State v. Martinez, 2007-NMSC-025, ¶ 9 , 141 N.M. 713 , 160 P.3d 894 (internal quotation marks and citation omitted); see also State v. Espinoza, 2023-NMCA-012 , ¶¶ 12-13, 525 P.3d 429 (distinguishing between the foundational evidence that supports the result of a scientific test and the result itself).

12025–2025
State v. Loza green
nmctapp · 2016
1 sentence

2016To this end, if an evidentiary issue is preserved by objection, we review the district court’s decision to admit or exclude evidence for an abuse of discretion, which means the decision was “clearly against the logic and effect of the facts and circumstances of the case.” State v. Loza, 2016-NMCA-088, ¶ 10 , 382 P.3d 963 (internal quotation marks and citation omitted).

12016–2016
State v. Anderson green
nm · 1994
2 sentences

1999On the contrary, the Alberico-Daubert standard explicitly incorporates “general acceptance” as a factor for courts to consider in determining the admissibility of scientific testimony, see Anderson, 118 N.M. at 299-300 , 881 P.2d at 44-45 , and we believe that the novel status of a particular scientific principle or procedure may be addressed in considering this factor.

1999On the contrary, the Alberico-Daubert standard explicitly incorporates “general acceptance” as a factor for courts to consider in determining the admissibility of scientific testimony, see Anderson, 118 N.M. at 299-300 , 881 P.2d at 44-45 , and we believe that the novel status of a particular scientific principle or procedure may be addressed in considering this factor.

11999–1999
Daubert v. Merrell Dow Pharmaceuticals, Inc. green
scotus · 1993
2 sentences

1998Id, In Daubert the Supreme Court determined that “‘the criterion of the scientific status of a theory is its refutability, falsifiability, or testability’ ” Daubert, 509 U.S. at 593 , 113 S.Ct. at 2797 (quoting Karl Popper, Conjectures and Refutations: The Growth of Scientific Knowledge 37 (5th ed.1989)). “‘Scientific methodology today is based on generating hypotheses and testing them to see if they can be falsified; indeed, this methodology is what distinguishes science from other fields of human inquiry.’ ” Daubert, 509 U.S. at 593 , 113 S.Ct. at 2796 (quoting Michael D.

1998Id, In Daubert the Supreme Court determined that “‘the criterion of the scientific status of a theory is its refutability, falsifiability, or testability’ ” Daubert, 509 U.S. at 593 , 113 S.Ct. at 2797 (quoting Karl Popper, Conjectures and Refutations: The Growth of Scientific Knowledge 37 (5th ed.1989)). “‘Scientific methodology today is based on generating hypotheses and testing them to see if they can be falsified; indeed, this methodology is what distinguishes science from other fields of human inquiry.’ ” Daubert, 509 U.S. at 593 , 113 S.Ct. at 2796 (quoting Michael D.

11998–1998
People v. Guerra green
cal · 1984
2 sentences

1993People v. Guerra, 37 Cal.3d 385 , 208 Cal.Rptr. 162 , 690 P.2d 635 (1984) (en banc).

1993People v. Guerra, 37 Cal.3d 385 , 208 Cal.Rptr. 162 , 690 P.2d 635 (1984) (en banc).

11993–1993
State v. Trimble red
nm · 1961
2 sentences

1966In State v. Trimble, 68 N.M. 406 , 362 P.2d 788 , we declined to admit the results of a polygraph test.

1966In State v. Trimble, 68 N.M. 406 , 362 P.2d 788 , we declined to admit the results of a polygraph test.

11966–1966

Statutes the citing opinions construe

NM § N.M. Stat. § 66-8-102 (6) NM § N.M. Stat. § 66-8-107 (4)

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

IL 133 (1979–2025) TX 87 (1957–2025) OH 84 (1923–2026) NY 81 (1938–2026) FL 78 (1979–2019) PA 69 (1944–2026) GA 47 (1981–2026) WA 44 (1978–2020) MD 41 (1977–2024) CA 40 (1933–2026) AZ 35 (1962–2025) AL 26 (1897–2014) NJ 25 (1974–2022) LA 21 (1975–2024) MO 20 (1915–2016) MN 20 (1971–2016) NM 18 (1966–2025) MI 17 (1949–2018) MA 17 (1978–2025) NE 16 (1949–2018) CT 16 (1963–2017) VA 15 (1984–2015) NC 13 (1914–2024) KS 13 (1982–2011) CO 12 (1981–2007) AK 12 (1983–2020) IN 12 (1980–2015) DC 12 (1979–2017) TN 11 (1997–2021) WV 11 (1903–2013) MS 11 (1912–2016) SD 11 (1979–2013) OR 10 (1976–2020) RI 9 (1980–2006) HI 9 (1999–2025) WI 9 (1974–2022) DE 8 (1985–2025) ME 6 (1954–2025) ID 5 (1984–2023) UT 5 (1980–1989) IA 5 (1980–2016) OK 4 (1994–2010) KY 4 (1974–2023) NH 4 (1969–2008) WY 3 (1982–2025) VT 2 (2010–2011)

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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