scientific principle (West Virginia) · Go Syfert
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scientific principle in West Virginia

11 West Virginia opinions name it 1 courts 1903–2013 0 in the last five years

The cases below were cited by West Virginia 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 8 West Virginia opinions naming this issue, 1980–2002
2 sentences

2002The seminal case [18] on the admissibility of scientific evidence is Frye v. United States, 293 F. 1013 , 54 App. D.C. 46 (1923), wherein the court succinctly stated: Just when a scientific principle or discovery crosses the line between the experimental and demonstrable stages is difficult to define.

2002The seminal case [18] on the admissibility of scientific evidence is Frye v. United States, 293 F. 1013 , 54 App. D.C. 46 (1923), wherein the court succinctly stated: Just when a scientific principle or discovery crosses the line between the experimental and demonstrable stages is difficult to define.

38
State v. Clawsongreen
wva · 1980 · cited in 4 West Virginia opinions naming this issue, 1988–2013
2 sentences

2013Syllabus point 1 of Barker provides that “ ‘[i]n order for a scientific test to be initially admissible, there must be general acceptance of the scientific principle which underlies the test.’ Syl. pt. 7, State v. Clawson, 165 W.Va. 588 , 270 S.E.2d 659 (1980).” We reject Ms. McCormick’s reliance on Syllabus point 1 of Barker .

2013Syllabus point 1 of Barker provides that “ ‘[i]n order for a scientific test to be initially admissible, there must be general acceptance of the scientific principle which underlies the test.’ Syl. pt. 7, State v. Clawson, 165 W.Va. 588 , 270 S.E.2d 659 (1980).” We reject Ms. McCormick’s reliance on Syllabus point 1 of Barker .

14
State v. Leepgreen
wva · 2002 · cited in 1 West Virginia opinions naming this issue, 2013–2013
2 sentences

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

11
State v. Armstronggreen
wva · 1988 · cited in 1 West Virginia opinions naming this issue, 1994–1994
2 sentences

1994As we stated in Syllabus Point 8 of Clawson , where the scientific test is generally accepted, it can be judicially noticed and the expert need not demonstrate its scientific validity. [5] We also stated in note 4 of State v. Armstrong, 179 W.Va. at 439-40, 369 S.E.2d at 874-75 (1988), that there is a general trend under Rule 702 to liberalize the Frye rule: "An increasing number of the courts and many of the leading commentators interpret Rule 702 of the Federal Rules of Evidence, which is identical to our Rule 702, as limiting the Frye `general acceptance' test to a test solely for determini

1994As we stated in Syllabus Point 8 of Clawson , where the scientific test is generally accepted, it can be judicially noticed and the expert need not demonstrate its scientific validity. [5] We also stated in note 4 of State v. Armstrong, 179 W.Va. at 439-40, 369 S.E.2d at 874-75 (1988), that there is a general trend under Rule 702 to liberalize the Frye rule: "An increasing number of the courts and many of the leading commentators interpret Rule 702 of the Federal Rules of Evidence, which is identical to our Rule 702, as limiting the Frye `general acceptance' test to a test solely for determini

11
State v. Woodallgreen
wva · 1989 · cited in 1 West Virginia opinions naming this issue, 1994–1994
2 sentences

1994Somewhere in this twilight zone the evidential force of the principle must be recognized, and 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." 54 App.D.C. at 47 , 293 F. at 1014 . [5] We elaborated on this point in State v. Woodall, 182 W.Va. 15, 22 , 385 S.E.2d 253, 260 (1989): "The basic reliability of scientific tests is often at issue when such evidence is ad

1994Somewhere in this twilight zone the evidential force of the principle must be recognized, and 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." 54 App.D.C. at 47 , 293 F. at 1014 . [5] We elaborated on this point in State v. Woodall, 182 W.Va. 15, 22 , 385 S.E.2d 253, 260 (1989): "The basic reliability of scientific tests is often at issue when such evidence is ad

11
United States v. Carl Joseph Baller, Jr.green
ca4 · 1975 · cited in 1 West Virginia opinions naming this issue, 1980–1980
1 sentence

1980United States v. Brown, 557 F.2d 541, 556 (6th Cir. 1977) (ion microprobic test for hair identification); United States v. Alexander, 526 F.2d 161, 163-164 (8th Cir. 1975) (polygraph); United States v. Bailer, 519 F.2d 463, 466 (4th Cir. W.

11
United States v. Steven John Alexandergreen
ca8 · 1975 · cited in 1 West Virginia opinions naming this issue, 1980–1980
1 sentence

1980United States v. Brown, 557 F.2d 541, 556 (6th Cir. 1977) (ion microprobic test for hair identification); United States v. Alexander, 526 F.2d 161, 163-164 (8th Cir. 1975) (polygraph); United States v. Bailer, 519 F.2d 463, 466 (4th Cir. W.

11
United States v. Hayward Leslie Browngreen
ca6 · 1977 · cited in 1 West Virginia opinions naming this issue, 1980–1980
2 sentences

1980United States v. Brown, 557 F.2d 541 (6th Cir. 1977); People v. Allweiss, 48 N.Y.2d 40 , 396 N.E.2d 735 , 421 N.Y.S.2d 341 (1979). *618 Undoubtedly there are certain scientific tests that have been widely used over a long period of time, such that their general acceptance in the scientific community can be judicially noticed.

1980United States v. Brown, 557 F.2d 541, 556 (6th Cir. 1977) (ion microprobic test for hair identification); United States v. Alexander, 526 F.2d 161, 163-164 (8th Cir. 1975) (polygraph); United States v. Bailer, 519 F.2d 463, 466 (4th Cir. W.

11
Reed v. Stategreen
md · 1978 · cited in 1 West Virginia opinions naming this issue, 1980–1980
2 sentences

1980Va. _, 267 S.E.2d 544, 550 (1980), recognized that one technique to ensure a fair trial where adverse publicity existed was to permit “a thorough and individual voir dire of the jury.” 14 Reed v. State, 283 Md. 374, 381 , 391 A.2d 364, 367-68 (1978), made this observation on the standard for reliability of a scientific test as it relates to a trial court’s discretion: “The question of the reliability of a scientific technique or process is unlike the question, for example, of the helpfulness of particular expert testimony to the trier of facts in a specific case.

1980Va. _, 267 S.E.2d 544, 550 (1980), recognized that one technique to ensure a fair trial where adverse publicity existed was to permit “a thorough and individual voir dire of the jury.” 14 Reed v. State, 283 Md. 374, 381 , 391 A.2d 364, 367-68 (1978), made this observation on the standard for reliability of a scientific test as it relates to a trial court’s discretion: “The question of the reliability of a scientific technique or process is unlike the question, for example, of the helpfulness of particular expert testimony to the trier of facts in a specific case.

11
State Ex Rel. Herald Mail Co. v. Hamiltongreen
wva · 1980 · cited in 1 West Virginia opinions naming this issue, 1980–1980
1 sentence

1980Va. _, 267 S.E.2d 544, 550 (1980), recognized that one technique to ensure a fair trial where adverse publicity existed was to permit “a thorough and individual voir dire of the jury.” 14 Reed v. State, 283 Md. 374, 381 , 391 A.2d 364, 367-68 (1978), made this observation on the standard for reliability of a scientific test as it relates to a trial court’s discretion: “The question of the reliability of a scientific technique or process is unlike the question, for example, of the helpfulness of particular expert testimony to the trier of facts in a specific case.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (14)

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

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

22002–2013
State v. Barker green
wva · 1988
2 sentences

1988In syllabus point 7 of State v. Clawson, 165 W.Va. 588 , 270 S.E.2d 659 (1980), the Court held: "In order for a scientific test to be initially admissible, there must be general acceptance of the scientific principle which underlies the test.” Accord, syl. pt. 1, State v. Barker, 179 W.Va. 194 , 366 S.E.2d 642 (1988) (Horizontal Gaze Nystag-mus test to estimate blood alcohol content).

1988In syllabus point 7 of State v. Clawson, 165 W.Va. 588 , 270 S.E.2d 659 (1980), the Court held: "In order for a scientific test to be initially admissible, there must be general acceptance of the scientific principle which underlies the test.” Accord, syl. pt. 1, State v. Barker, 179 W.Va. 194 , 366 S.E.2d 642 (1988) (Horizontal Gaze Nystag-mus test to estimate blood alcohol content).

21988–1994
Gentry v. Mangum green
wva · 1995
2 sentences

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

12013–2013
Wilt v. Buracker green
wva · 1994
2 sentences

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

2013First, Ms. McCormick has failed to realize that the “general acceptance” test under Barker and Clawson was expressly overruled by Wilt v. Buracker, 191 W.Va. 39 , 443 S.E.2d 196 (1993). 11 See State v. Leep, 212 W.Va. 57, 67 , 569 S.E.2d 133, 143 (2002) (“[T]he prior ‘general acceptance’ standard ... is obsolete and has been replaced by the more liberal determinative criteria enunciated in Daubert [v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 , 125 L.Ed.2d 469 (1993)1 Wilt, Gentry [v. Mangum, 195 W.Va. 512 , 466 S.E.2d 171 (1995) ], and Rule 702 of the Federal and West V

12013–2013
Bullcoming v. New Mexico green
scotus · 2011
2 sentences

2012Second, she noted that the surrogate expert was not a “supervisor, reviewer, or someone else with a personal, albeit limited, connection to the scientific test at issue.” Id.

2012Rather, the surrogate “played no role in producing the BAC report and did not observe any portion of [the analyst’s] conduct of the testing.” Id.

12012–2012
Geary Land Co. v. Conley green
wva · 1985
2 sentences

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

11988–1988
McAllister v. Weirton Hospital Co. green
wva · 1983
2 sentences

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

11988–1988
Boggs v. Settle green
wva · 1965
2 sentences

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

11988–1988
ORIGINAL GLORIOUS CHURCH OF GOD v. Myers green
wva · 1988
1 sentence

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

11988–1988
Original Glorious Church of God In Christ, Inc. of the Apostolic Faith v. Myers green
wva · 1988
1 sentence

1988We need not reach the Frye issue in the present case. 4 The harmless error rule, Rule 61 of the West Virginia Rules of Civil Procedure, applies to this assignment of error involving the admissibility of expert testimony on the novel prosthesis. 5 In syllabus point 2 of Boggs v. Settle, 150 W.Va. 330 , 145 S.E.2d 446 (1965), the Court held: “On appeal of a case involving an action covered by the Rules of Civil Procedure, this Court will disregard and regard as harmless any error, defect or irregularity in the proceedings in the trial court which does not affect the substantial rights of the par

11988–1988
State v. Hood green
wva · 1971
1 sentence

1980In State v. Hood, 155 W.

11980–1980
People v. Allweiss green
ny · 1979
2 sentences

1980United States v. Brown, 557 F.2d 541 (6th Cir. 1977); People v. Allweiss, 48 N.Y.2d 40 , 396 N.E.2d 735 , 421 N.Y.S.2d 341 (1979). *618 Undoubtedly there are certain scientific tests that have been widely used over a long period of time, such that their general acceptance in the scientific community can be judicially noticed.

1980United States v. Brown, 557 F.2d 541 (6th Cir. 1977); People v. Allweiss, 48 N.Y.2d 40 , 396 N.E.2d 735 , 421 N.Y.S.2d 341 (1979). *618 Undoubtedly there are certain scientific tests that have been widely used over a long period of time, such that their general acceptance in the scientific community can be judicially noticed.

11980–1980
Insurance Co. v. Boon green
· 1877
1 sentence

1903J., said: “That which is the actual cause of the loss, whether operating directly or by putting intervening agencies, the operation of which could not be reasonably avoided, in motion, by which the loss is produced, is the cause to which such loss should be attributed.” These principles are approved in Insurance Co. v. Boon, 95 U. S. 117 .

11903–1903
Brady v. North Western Insurance neutral
· 1863
1 sentence

1903Phillips on Insurance, Section 1093, says: “If two causes conspire and one must be chosen, the more scientific inquiry seems to be, whether one is not the efficient cause, and the other merely instrumental or merely incidental, and not which is nearer in place or time to the consummation of the catastrophe.” At Section 1132, the same work says: “In case of the concurrence of different causes, to one of which it is necessary to attribute the' loss, it is to be attributed to the efficient predominating peril, whether it is or is not in activity at the consummation of the disaster.” In Brady v. I

11903–1903

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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