Frye standard in Arkansas

8 Arkansas opinions name it 3 courts 1989–1996 0 in the last five years

The cases below were cited by Arkansas 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 (4)

Case	Followed	Cited
Dumond v. Stategreen ark · 1988 · cited in 3 Arkansas opinions naming this issue, 1989–1993 2 sentences 1989Although it is unclear whether some form of the Frye test may be applicable in Arkansas, see Dumond v. State, 294 Ark. 379 , 743 S.W.2d 779 (1988), we need not decide this issue because, like the Supreme Court in Rock, we conclude that the foundation for the scientific evidence in the case at bar was inadequate under either the Frye test or the Arkansas Rules of Evidence. 1989Although it is unclear whether some form of the Frye test may be applicable in Arkansas, see Dumond v. State, 294 Ark. 379 , 743 S.W.2d 779 (1988), we need not decide this issue because, like the Supreme Court in Rock, we conclude that the foundation for the scientific evidence in the case at bar was inadequate under either the Frye test or the Arkansas Rules of Evidence.	2	3
Prater v. Stategreen ark · 1991 · cited in 4 Arkansas opinions naming this issue, 1992–1993 2 sentences 1993Indeed, this court previously reached the same conclusion in Prater v. State, 307 Ark. 180 , 820 S.W.2d 429 (1991), rejecting the Frye standard for the relevancy approach implicit in A.R.E. 401. 1993Indeed, this court previously reached the same conclusion in Prater v. State, 307 Ark. 180 , 820 S.W.2d 429 (1991), rejecting the Frye standard for the relevancy approach implicit in A.R.E. 401.	1	4
Frye v. United Statesred cadc · 1923 · cited in 1 Arkansas opinions naming this issue, 1993–1993 2 sentences 1993See Frye v. United States, 293 F. 1013 (D.C.Cir. 1923). 1993See Frye v. United States, 293 F. 1013 (D.C.Cir. 1923).	1	1
Caldwell v. Stategreen ga · 1990 · cited in 1 Arkansas opinions naming this issue, 1991–1991 2 sentences 1991The significant point is that the trial court makes this determination based on the evidence available to him rather than by simply calculating the consensus in the scientific community.” Caldwell v. State, 260 Ga. 278, 285-86 , 393 S.E.2d 436, 441 (1990). 1991The significant point is that the trial court makes this determination based on the evidence available to him rather than by simply calculating the consensus in the scientific community.” Caldwell v. State, 260 Ga. 278, 285-86 , 393 S.E.2d 436, 441 (1990).	1	1

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Arkansas. Read the followed side critically anyway.

Also cited on this issue (9)

Case	Cited	Years
Rock v. State green ark · 1986 2 sentences 1991Although it labeled the hearing as such, the trial court noted that this court has not yet decided whether to adopt the Frye standard of admissibility (see Rock v. State, 288 Ark. 566 , 708 S.W.2d 78 (1986)), and thus considered the matter in light of both Frye and the Arkansas Rules of Evidence. 1991Although it labeled the hearing as such, the trial court noted that this court has not yet decided whether to adopt the Frye standard of admissibility (see Rock v. State, 288 Ark. 566 , 708 S.W.2d 78 (1986)), and thus considered the matter in light of both Frye and the Arkansas Rules of Evidence.	2	1989–1991
Daubert v. Merrell Dow Pharmaceuticals, Inc. green scotus · 1993 2 sentences 1996In 1993, the U.S. Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 (1993), held that the Federal Rules of Evidence supersede the Frye test and that the admissibility of expert opinion testimony concerning novel scientific evidence would no longer be limited solely to knowledge or evidence generally accepted as reliable in the relevant scientific community. 1996In 1993, the U.S. Supreme Court in Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , 113 S.Ct. 2786 (1993), held that the Federal Rules of Evidence supersede the Frye test and that the admissibility of expert opinion testimony concerning novel scientific evidence would no longer be limited solely to knowledge or evidence generally accepted as reliable in the relevant scientific community.	1	1996–1996
State v. Davis green mo · 1991 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
Glover v. State green texapp · 1990 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
State v. Schwartz green minn · 1989 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
Smith v. Deppish green kan · 1991 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
State v. Woodall green wva · 1989 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
State v. Ford green sc · 1990 2 sentences 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W. 1991The following courts have held DNA testing is admissible as forensic evidence under the Frye standard: Smith v. Deppish, 248 Kan. 217 , 807 P.2d 144 (1991); State v. Schwartz, 447 N.W.2d 422 (Minn. 1989); State v. Davis, No. 71694, 1991 WL 134460 (Mo. July 23, 1991); State v. Ford, 392 S.E.2d 781 (S.C. 1990); Glover v. State, 787 S.W.2d 544 (Tex. Ct. App. 1990); State v. Woodall, 385 S.E.2d 253 (W.	1	1991–1991
Rock v. Arkansas green scotus · 1987 2 sentences 1989In Rock v. State, 288 Ark. 566 , 708 S.W.2d 78 (1986), vacated on other grounds 483 U.S. —, 107 S. Ct. 2704 (1987), the Court declined to decidewhether to employ the Frye test or an analysis based entirely on the Arkansas Rules of Evidence because the Court found the hypnotically-induced testimony at issue in Rock to be inadmissible under either approach. 1989In Rock v. State, 288 Ark. 566 , 708 S.W.2d 78 (1986), vacated on other grounds 483 U.S. —, 107 S. Ct. 2704 (1987), the Court declined to decidewhether to employ the Frye test or an analysis based entirely on the Arkansas Rules of Evidence because the Court found the hypnotically-induced testimony at issue in Rock to be inadmissible under either approach.	1	1989–1989

Where else courts name it

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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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