Frye test (Rhode Island) · Go Syfert
← Rhode Island issues

Frye test in Rhode Island

7 Rhode Island opinions name it 2 courts 1985–2020 0 in the last five years

The cases below were cited by Rhode Island 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 (6)

CaseFollowedCited
Daubert v. Merrell Dow Pharmaceuticals, Inc.green
scotus · 1993 · cited in 3 Rhode Island opinions naming this issue, 1996–1999
2 sentences

1999The Court went on to explain that the fact that seventy years had elapsed before “the Frye test was displaced by the Rules of Evidence does not mean * * * that the Rules themselves place no limits on the admissibility of purportedly scientific evidence.” Id. at 589, 113 S.Ct. at 2794-95 , 125 L.Ed.2d at 480 .

1999The Court went on to explain that the fact that seventy years had elapsed before “the Frye test was displaced by the Rules of Evidence does not mean * * * that the Rules themselves place no limits on the admissibility of purportedly scientific evidence.” Id. at 589, 113 S.Ct. at 2794-95 , 125 L.Ed.2d at 480 .

23
State v. Williamsgreen
ohio · 1983 · cited in 2 Rhode Island opinions naming this issue, 1985–1985
2 sentences

1985Since scientific proof may in some instances assume a posture of mystic infallibility in the eyes of a jury of laymen, the ability to produce rebuttal experts, equally conversant with the mechanics and methods of a particular technique, may prove to be essential.” State v. Williams, 4 Ohio St.3d 53, 56-57 , 446 N.E.2d 444, 446 (1983) (quoting United States v. Addison, 498 F.2d 741, 744 (D.C.Cir.1974)).

1985Since scientific proof may in some instances assume a posture of mystic infallibility in the eyes of a jury of laymen, the ability to produce rebuttal experts, equally conversant with the mechanics and methods of a particular technique, may prove to be essential.” State v. Williams, 4 Ohio St.3d 53, 56-57 , 446 N.E.2d 444, 446 (1983) (quoting United States v. Addison, 498 F.2d 741, 744 (D.C.Cir.1974)).

22
United States v. Roland Addison, United States of America v. Albert Henry Raymondgreen
cadc · 1974 · cited in 2 Rhode Island opinions naming this issue, 1985–1985
2 sentences

1985Since scientific proof may in some instances assume a posture of mystic infallibility in the eyes of a jury of laymen, the ability to produce rebuttal experts, equally conversant with the mechanics and methods of a particular technique, may prove to be essential.” State v. Williams, 4 Ohio St.3d 53, 56-57 , 446 N.E.2d 444, 446 (1983) (quoting United States v. Addison, 498 F.2d 741, 744 (D.C.Cir.1974)).

1985Since scientific proof may in some instances assume a posture of mystic infallibility in the eyes of a jury of laymen, the ability to produce rebuttal experts, equally conversant with the mechanics and methods of a particular technique, may prove to be essential.” State v. Williams, 4 Ohio St.3d 53, 56-57 , 446 N.E.2d 444, 446 (1983) (quoting United States v. Addison, 498 F.2d 741, 744 (D.C.Cir.1974)).

22
State v. Wheelergreen
ri · 1985 · cited in 2 Rhode Island opinions naming this issue, 1996–1999
2 sentences

1999In Wheeler , the Rhode Island Supreme Court, after discussing various opinions regarding the Frye test, held: "[W]here the subject matter of the testimony is of a mechanical, scientific, professional or like nature, none of which is within the understanding of laymen of ordinary intelligence, and where the witness seeking to testify possesses special knowledge, skill or information about the subject matter acquired by study, observation, practice or experience, the trial justice must determine if `such an individual's opinion may be heard as aid to the jury in its quest to discover the truth.'

1999In Wheeler , the Rhode Island Supreme Court, after discussing various opinions regarding the Frye test, held: "[W]here the subject matter of the testimony is of a mechanical, scientific, professional or like nature, none of which is within the understanding of laymen of ordinary intelligence, and where the witness seeking to testify possesses special knowledge, skill or information about the subject matter acquired by study, observation, practice or experience, the trial justice must determine if `such an individual's opinion may be heard as aid to the jury in its quest to discover the truth.'

12
State v. Quattrocchigreen
ri · 1996 · cited in 1 Rhode Island opinions naming this issue, 1999–1999
2 sentences

1999Daubert , 509 U.S. at 587 , 113 S.Ct. at 2793 , 125 L.Ed.2d at 479 ; Quattrocchi , 681 A.2d at 884, n.2 .

1999Daubert , 509 U.S. at 587 , 113 S.Ct. at 2793 , 125 L.Ed.2d at 479 ; Quattrocchi , 681 A.2d at 884, n.2 .

11
Frye v. United Statesred
cadc · 1923 · cited in 1 Rhode Island opinions naming this issue, 1996–1996
2 sentences

1996The Frye standard requires a scientific methodology to be “sufficiently established to have gained general acceptance in the particular field in which it belongs." Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , -, 113 S.Ct. 2786, 2793 , 125 L.Ed.2d 469, 478 (1993) (quoting Frye v. United States, 54 App.D.C. 46, 47 , 293 F. 1013, 1014 (1923)). 2 .

1996The Frye standard requires a scientific methodology to be “sufficiently established to have gained general acceptance in the particular field in which it belongs." Daubert v. Merrell Dow Pharmaceuticals, Inc., 509 U.S. 579 , -, 113 S.Ct. 2786, 2793 , 125 L.Ed.2d 469, 478 (1993) (quoting Frye v. United States, 54 App.D.C. 46, 47 , 293 F. 1013, 1014 (1923)). 2 .

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (6)

CaseCitedYears
State v. Williams green
me · 1978
2 sentences

1985The Supreme Judicial Court of Maine in State v. Williams, 388 A.2d 500 (Me.1978), which had adopted a state code of evidence fashioned after the Federal Rules of Evidence, nevertheless concluded that “[t]he controlling criteria regarding the admissibility of expert testimony, so long as the proffered expert is qualified and probative value is not substantially outweighed by the factors mentioned in Rule 403, [considerations of prejudice, confusion, or waste of time] are whether in the sound judgment of the presiding Justice the testimony to be given is relevant and will assist the trier of fac

1985The Supreme Judicial Court of Maine in State v. Williams, 388 A.2d 500 (Me.1978), which had adopted a state code of evidence fashioned after the Federal Rules of Evidence, nevertheless concluded that “[t]he controlling criteria regarding the admissibility of expert testimony, so long as the proffered expert is qualified and probative value is not substantially outweighed by the factors mentioned in Rule 403, [considerations of prejudice, confusion, or waste of time] are whether in the sound judgment of the presiding Justice the testimony to be given is relevant and will assist the trier of fac

21985–1985
Commonwealth v. Lykus green
mass · 1975
2 sentences

1985We note that the Supreme Judicial Court of Massachusetts in Commonwealth v. Lykus, 367 Mass. 191 , 327 N.E.2d 671 (1975), applied the Frye standard and approved the admission of voice speetro-graphic evidence, stating that “[ljimited in number though the experts may be, the requirement of the Frye rule of general acceptability is satisfied, in our opinion, if the principle is generally accepted by those who would be expected to be familiar with its use.” Id. at 203, 327 N.E.2d at 677 .

1985We note that the Supreme Judicial Court of Massachusetts in Commonwealth v. Lykus, 367 Mass. 191 , 327 N.E.2d 671 (1975), applied the Frye standard and approved the admission of voice speetro-graphic evidence, stating that “[ljimited in number though the experts may be, the requirement of the Frye rule of general acceptability is satisfied, in our opinion, if the principle is generally accepted by those who would be expected to be familiar with its use.” Id. at 203, 327 N.E.2d at 677 .

21985–1985
Missouri v. Frye green
scotus · 2012
2 sentences

2020Before the trial started, and because a plea offer had been made to defendant (which would have resulted in a disposition not requiring incarceration), the trial justice held a hearing to address the concerns raised in Missouri v. Frye, 566 U.S. 134 (2012).1 At the Frye hearing, the trial justice asked defendant if his lawyer had spoken with him about the elements of the charges that the state would have to prove beyond a reasonable doubt, and defendant responded, “Yes.” The trial justice then specifically inquired about the charge of assault with a dangerous weapon as follows: “THE COURT: [D]

2020Before the trial started, and because a plea offer had been made to defendant (which would have resulted in a disposition not requiring incarceration), the trial justice held a hearing to address the concerns raised in Missouri v. Frye, 566 U.S. 134 (2012).1 At the Frye hearing, the trial justice asked defendant if his lawyer had spoken with him about the elements of the charges that the state would have to prove beyond a reasonable doubt, and defendant responded, “Yes.” The trial justice then specifically inquired about the charge of assault with a dangerous weapon as follows: “THE COURT: [D]

12020–2020
Lafler v. Cooper green
scotus · 2012
1 sentence

2020There is no dispute that the state made a plea offer to the defendant, that a hearing was held during which the trial justice made the defendant aware of the offer and was satisfied that he understood the elements of the crimes of which he was charged, and that the defendant chose to reject the state’s offer.6 As we have explained supra, aiding and abetting is not an additional element of the crime of assault with a dangerous weapon, such that the defendant needed to understand its nature in order to properly 6 The defendant’s reliance on Lafler v. Cooper, 566 U.S. 156 (2012), is also misplace

12020–2020
State v. Breen green
ri · 2001
2 sentences

2020A Frye hearing is not “an issue of constitutional dimension derived from a novel rule of law that could not reasonably have been known to counsel at the time of trial.” Breen, 767 A.2d at 57 .

2020A Frye hearing is not “an issue of constitutional dimension derived from a novel rule of law that could not reasonably have been known to counsel at the time of trial.” Breen, 767 A.2d at 57 .

12020–2020
State v. Dery green
ri · 1988
2 sentences

1999However, the Dery court reversed the trial court's decision to admit the results of a polygraph examination which supported defendant's claim of truthfulness and reaffirmed Frye by stating that ". . . before a scientific principle or discovery may be considered for its evidentiary value, it must be `sufficiently established to have gained general acceptance in the particular field in which it belongs.'" State v. Dery , 545 A.2d 1014 , 1016 (R.I. 1988).

1999However, the Dery court reversed the trial court's decision to admit the results of a polygraph examination which supported defendant's claim of truthfulness and reaffirmed Frye by stating that ". . . before a scientific principle or discovery may be considered for its evidentiary value, it must be `sufficiently established to have gained general acceptance in the particular field in which it belongs.'" State v. Dery , 545 A.2d 1014 , 1016 (R.I. 1988).

11999–1999

Where else courts name it

NY 400 (1979–2026) IL 306 (1983–2026) PA 242 (1977–2026) WA 222 (1978–2026) FL 180 (1983–2026) CA 140 (1976–2026) MD 60 (1978–2025) AZ 59 (1982–2016) NJ 55 (1978–2026) KS 49 (1981–2026) MO 47 (1985–2024) TX 38 (1984–2026) MA 34 (1975–2026) AL 33 (1984–2017) CO 31 (1981–2021) MN 29 (1980–2026) CT 29 (1984–2005) NE 25 (1992–2017) MS 25 (1990–2008) DC 23 (1979–2026) AK 23 (1983–2019) MI 22 (1977–2024) OH 20 (1975–2023) IN 17 (1984–2023) VA 17 (1988–2010) WV 15 (1980–2026) SD 15 (1985–2026) KY 10 (1991–2015) DE 10 (1985–2025) ID 10 (1984–2013) WI 10 (1981–2021) NM 10 (1993–2016) TN 10 (1986–2014) NH 9 (1992–2004) GA 9 (1982–2020) UT 8 (1980–2019) AR 8 (1989–1996) IA 8 (1986–2025) OR 7 (1984–2024) HI 7 (1992–2026) MT 7 (1991–2026) LA 7 (1982–2018) RI 7 (1985–2020) VT 6 (1993–2009) NC 6 (1984–2004) OK 6 (1994–2025) WY 6 (1983–2025) SC 5 (1990–2026) ND 4 (1983–2005) ME 3 (1978–2011)

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.

← Caselaw search · G Cite Topics · Brief Check