Frye test (Kansas) · Go Syfert
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Frye test in Kansas

49 Kansas opinions name it 2 courts 1981–2026 1 in the last five years

The cases below were cited by Kansas 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 (28)

CaseFollowedCited
Frye v. United Statesred
cadc · 1923 · cited in 20 Kansas opinions naming this issue, 1990–2026
2 sentences

2026The issue in Smith was rather whether Daubert's "gatekeeping" rule precluded a jury from considering a novel and controversial scientific theory of causation that, while plausible, was on the "outer rim of supportable science." 2004 WL 870832 , at *1. 12 In finding that the experts could testify to that theory, the Smith court distinguished between Frye's general acceptance test and Daubert's reliability test for the content of expert opinions: "As conceived by the Supreme Court, Daubert was intended to supplant the inflexible and ultra-orthodox 'general acceptance' test of Frye v. United Stat

2026The issue in Smith was rather whether Daubert's "gatekeeping" rule precluded a jury from considering a novel and controversial scientific theory of causation that, while plausible, was on the "outer rim of supportable science." 2004 WL 870832 , at *1. 12 In finding that the experts could testify to that theory, the Smith court distinguished between Frye's general acceptance test and Daubert's reliability test for the content of expert opinions: "As conceived by the Supreme Court, Daubert was intended to supplant the inflexible and ultra-orthodox 'general acceptance' test of Frye v. United Stat

920
Kuhn v. Sandoz Pharmaceuticals Corp.green
kan · 2000 · cited in 11 Kansas opinions naming this issue, 2002–2017
2 sentences

2017See City of Wichita v. Molitor, 301 Kan. 251, 257 , 341 P.3d 1275 (2015) ("[W]hether the district court failed to correctly apply the Frye standard for the admissibility of scientific evidence is an abstract question of law subject to de novo review.") (citing Kuhn v. Sandoz Pharmaceuticals Corp., 270 Kan. 443, 455-56 , 14 P.3d 1170 [2000]).

2017See City of Wichita v. Molitor, 301 Kan. 251, 257 , 341 P.3d 1275 (2015) ("[W]hether the district court failed to correctly apply the Frye standard for the admissibility of scientific evidence is an abstract question of law subject to de novo review.") (citing Kuhn v. Sandoz Pharmaceuticals Corp., 270 Kan. 443, 455-56 , 14 P.3d 1170 [2000]).

511
State v. Wittegreen
kan · 1992 · cited in 5 Kansas opinions naming this issue, 1995–2015
2 sentences

2015Notwithstanding Witte’s clear directive that a trial court must first “examine, weigh, and decide disputed facts to determine whether the [HGN] test is sufficiently reliable to be admissible for any purpose in Kansas,” State v. Witte, 251 Kan. 313, 330 , 836 P.3d 1110 (1992), the Court of Appeals made the curious declaration that “[i]t is important to note that tire issue presented in this case is not whether HGN testing has now reached the level of acceptance to satisfy the Frye test.” City of Wichita v. Molitor, 46 Kan.

2015Notwithstanding Witte’s clear directive that a trial court must first “examine, weigh, and decide disputed facts to determine whether the [HGN] test is sufficiently reliable to be admissible for any purpose in Kansas,” State v. Witte, 251 Kan. 313, 330 , 836 P.3d 1110 (1992), the Court of Appeals made the curious declaration that “[i]t is important to note that tire issue presented in this case is not whether HGN testing has now reached the level of acceptance to satisfy the Frye test.” City of Wichita v. Molitor, 46 Kan.

35
State v. Shaddengreen
kan · 2010 · cited in 5 Kansas opinions naming this issue, 2011–2017
2 sentences

2017The Frye test required a "showing that the basis of a scientific opinion is generally accepted as reliable within the expert's particular scientific field." State v. Shadden, 290 Kan. 803, 819 , 235 P.3d 436 (2010).

2017The Frye test required a "showing that the basis of a scientific opinion is generally accepted as reliable within the expert's particular scientific field." State v. Shadden, 290 Kan. 803, 819 , 235 P.3d 436 (2010).

25
State v. Hodgesgreen
kan · 1986 · cited in 2 Kansas opinions naming this issue, 1991–1995
2 sentences

1995See State v. Hodges, 239 Kan. 63, 71 , 716 P.2d 563 (1986).” Other states have likewise allowed admission of PCR DNA test results.

1995See State v. Hodges, 239 Kan. 63, 71 , 716 P.2d 563 (1986).” Other states have likewise allowed admission of PCR DNA test results.

22
Daubert v. Merrell Dow Pharmaceuticals, Inc.green
scotus · 1993 · cited in 9 Kansas opinions naming this issue, 2000–2026
2 sentences

2026The issue in Smith was rather whether Daubert's "gatekeeping" rule precluded a jury from considering a novel and controversial scientific theory of causation that, while plausible, was on the "outer rim of supportable science." 2004 WL 870832 , at *1. 12 In finding that the experts could testify to that theory, the Smith court distinguished between Frye's general acceptance test and Daubert's reliability test for the content of expert opinions: "As conceived by the Supreme Court, Daubert was intended to supplant the inflexible and ultra-orthodox 'general acceptance' test of Frye v. United Stat

2026The issue in Smith was rather whether Daubert's "gatekeeping" rule precluded a jury from considering a novel and controversial scientific theory of causation that, while plausible, was on the "outer rim of supportable science." 2004 WL 870832 , at *1. 12 In finding that the experts could testify to that theory, the Smith court distinguished between Frye's general acceptance test and Daubert's reliability test for the content of expert opinions: "As conceived by the Supreme Court, Daubert was intended to supplant the inflexible and ultra-orthodox 'general acceptance' test of Frye v. United Stat

19
In re the Care & Treatment of Girardgreen
kan · 2013 · cited in 4 Kansas opinions naming this issue, 2013–2020
2 sentences

2020The Frye test requires that before expert scientific opinion may be admitted into evidence, the basis of the opinion must be generally accepted as reliable within the expert's particular field. 296 Kan. at 376 .

2020The Frye test requires that before expert scientific opinion may be admitted into evidence, the basis of the opinion must be generally accepted as reliable within the expert's particular field. 296 Kan. at 376 .

14
State v. Canaangreen
kan · 1998 · cited in 3 Kansas opinions naming this issue, 2000–2017
2 sentences

2017On the other hand, the requirement that the State undertake the burden to satisfy the Frye test and prove the reliability of the underlying scientific theory upon which the expert opinion is based arises "[o]nly when there is a doubt as to the scientific reliability of evidence." Canaan, 265 Kan. at 849 .

2017On the other hand, the requirement that the State undertake the burden to satisfy the Frye test and prove the reliability of the underlying scientific theory upon which the expert opinion is based arises "[o]nly when there is a doubt as to the scientific reliability of evidence." Canaan, 265 Kan. at 849 .

13
State v. Hillgreen
kan · 1995 · cited in 3 Kansas opinions naming this issue, 1995–2013
2 sentences

2013See State v. Hill, 257 Kan. 774 , 895 P.2d 1238 (1995) (PCR analysis met Frye test).

2013See State v. Hill, 257 Kan. 774 , 895 P.2d 1238 (1995) (PCR analysis met Frye test).

13
State v. Isleygreen
kan · 1997 · cited in 3 Kansas opinions naming this issue, 1999–2013
2 sentences

2013The court first noted that “DNA testing meets the Frye test in Kansas.” 262 Kan. at 285 .

2013The court first noted that “DNA testing meets the Frye test in Kansas.” 262 Kan. at 285 .

13
State v. Marksgreen
kan · 1982 · cited in 3 Kansas opinions naming this issue, 1995–2008
2 sentences

2008In State v. Marks, 231 Kan. 645, 654 , 647 P.2d 1292 (1982), the court upheld the district court’s admission of expert testimony from a psychiatrist about rape-trauma syndrome because a review of medical literature showed that it was “generally accepted to be a common reaction to sexual assault.” Similarly, in State v Heath, 264 Kan. 557, 574-75, 577-78 , 957 P.2d 449 (1998), the court held that battered-child syndrome was “an accepted medical diagnosis” such that — even though the testimony was subject to the Frye test — the district court didn’t need to hold a Frye hearing because courts had

2008In State v. Marks, 231 Kan. 645, 654 , 647 P.2d 1292 (1982), the court upheld the district court’s admission of expert testimony from a psychiatrist about rape-trauma syndrome because a review of medical literature showed that it was “generally accepted to be a common reaction to sexual assault.” Similarly, in State v Heath, 264 Kan. 557, 574-75, 577-78 , 957 P.2d 449 (1998), the court held that battered-child syndrome was “an accepted medical diagnosis” such that — even though the testimony was subject to the Frye test — the district court didn’t need to hold a Frye hearing because courts had

13
State v. Haddockred
kan · 1995 · cited in 2 Kansas opinions naming this issue, 1995–1997
2 sentences

1997Hill, 257 Kan. 783 -85; see State v. Haddock, 257 Kan. 964, 983-85 , 897 P.2d 152 (1995); MacKnight, The Polymerase Chain Reaction (PCR): The Second Generation of DNA Analysis Methods Takes the Stand, 9 Santa Clara Computer & High Tech.

1997Hill, 257 Kan. 783 -85; see State v. Haddock, 257 Kan. 964, 983-85 , 897 P.2d 152 (1995); MacKnight, The Polymerase Chain Reaction (PCR): The Second Generation of DNA Analysis Methods Takes the Stand, 9 Santa Clara Computer & High Tech.

12
Fredricks v. Foltzgreen
kan · 1976 · cited in 1 Kansas opinions naming this issue, 2020–2020
11
City of Wichita v. Molitorgreen
kan · 2015 · cited in 1 Kansas opinions naming this issue, 2017–2017
11
City of Wichita v. Molitorgreen
kanctapp · 2012 · cited in 1 Kansas opinions naming this issue, 2015–2015
11
In Re the Care & Treatment of Girardgreen
kanctapp · 2011 · cited in 1 Kansas opinions naming this issue, 2013–2013
11
Ortega-Mantilla v. Stategreen
fladistctapp · 2005 · cited in 1 Kansas opinions naming this issue, 2013–2013
11
State v. Elnickigreen
kan · 2005 · cited in 1 Kansas opinions naming this issue, 2010–2010
11
State v. Heathgreen
kan · 1998 · cited in 1 Kansas opinions naming this issue, 2008–2008
11
In Re the Appeal of Panhandle Eastern Pipe Line Co.green
kan · 2002 · cited in 1 Kansas opinions naming this issue, 2003–2003
11
State v. Golstongreen
kan · 2000 · cited in 1 Kansas opinions naming this issue, 2002–2002
11
Florida Power & Light Co. v. Tursigreen
fladistctapp · 1999 · cited in 1 Kansas opinions naming this issue, 2000–2000
11
Baker v. Dalkon Shield Trustgreen
ca1 · 1998 · cited in 1 Kansas opinions naming this issue, 2000–2000
11
Blum Ex Rel. Blum v. Merrell Dow Pharmaceuticals, Inc.green
pasuperct · 1997 · cited in 1 Kansas opinions naming this issue, 2000–2000
11
Keene Corp. v. Hallgreen
mdctspecapp · 1993 · cited in 1 Kansas opinions naming this issue, 2000–2000
11
State v. Superior Courtgreen
ariz · 1986 · cited in 1 Kansas opinions naming this issue, 1992–1992
11
People v. Castrogreen
nysupct · 1989 · cited in 1 Kansas opinions naming this issue, 1991–1991
11
State v. Menagreen
ariz · 1981 · cited in 1 Kansas opinions naming this issue, 1985–1985
11

Distinguished, questioned or overruled (1)

CaseNegativeCited
State Ex Rel. Romley v. Fieldsgreen
arizctapp · 2001 · cited in 1 Kansas opinions naming this issue, 2013–2013
11

Also cited on this issue (49)

CaseCitedYears
State v. Lowry green
kan · 1947
2 sentences

2000We adopted the Frye test in State v. Lowry, 163 Kan. 622, 629 , 185 P.2d 147 (1947).

2000We adopted the Frye test in State v. Lowry, 163 Kan. 622, 629 , 185 P.2d 147 (1947).

71991–2010
State v. Washington green
kan · 1981
2 sentences

2000In State v. Washington, 229 Kan. 47, 54 , 622 P.2d 986 (1981), we identified the purpose of the Frye test: *455 “ ‘Frye was deliberately intended to interpose a substantial obstacle to the unrestrained admission of evidence based upon new scientific principles. . . .Several reasons founded in logic and common sense support a posture of judicial caution in this area.

2000In State v. Washington, 229 Kan. 47, 54 , 622 P.2d 986 (1981), we identified the purpose of the Frye test: *455 “ ‘Frye was deliberately intended to interpose a substantial obstacle to the unrestrained admission of evidence based upon new scientific principles. . . .Several reasons founded in logic and common sense support a posture of judicial caution in this area.

51982–2000
Smith v. Deppish green
kan · 1991
2 sentences

1995Our description of the Frye test in Deppish, 248 Kan. at 236 , and Dr. Giles’ testimony that the Haddock samples were subjected to the laboratory analysis described in his testimony disposes of Haddock’s contention on appeal that the procedures used in the instant case were not established.

1995Our description of the Frye test in Deppish, 248 Kan. at 236 , and Dr. Giles’ testimony that the Haddock samples were subjected to the laboratory analysis described in his testimony disposes of Haddock’s contention on appeal that the procedures used in the instant case were not established.

41995–2013
State v. Miller green
kan · 1987
2 sentences

1998Additionally, Canaan argues for the first time on appeal that there was no evidence that “John Wilson was qualified to testify as an expert in the field of luminol testing techniques or as to the validity and reliability of the exact techniques he used in this case.” Canaan cites State v. Miller, 240 Kan. 733 , 732 P.2d 756 (1987), and State v. Witte, 251 Kan. 313 , 836 P.2d 1110 (1992), for the proposition that the Frye test is both an evidentiary and foundational standard.

1998Additionally, Canaan argues for the first time on appeal that there was no evidence that “John Wilson was qualified to testify as an expert in the field of luminol testing techniques or as to the validity and reliability of the exact techniques he used in this case.” Canaan cites State v. Miller, 240 Kan. 733 , 732 P.2d 756 (1987), and State v. Witte, 251 Kan. 313 , 836 P.2d 1110 (1992), for the proposition that the Frye test is both an evidentiary and foundational standard.

31990–1998
Reed v. State green
md · 1978
2 sentences

1982Reed v. State, 283 Md. 374 , 391 A.2d 364 (1978).

1982Reed v. State, 283 Md. 374 , 391 A.2d 364 (1978).

31981–1982
State v. Shively green
kan · 2000
2 sentences

2017De novo review is appropriate in such circumstances "because the outcome of a Frye holding transcends individual cases such that applying less than a de novo standard could lead to inconsistent treatment of similarly situated claims." State v. Shively, 268 Kan. 573, 576 , 999 P.2d 952 (2000). 30 The State, on the other hand, contends that the abuse of discretion standard is appropriate because the actual question presented is whether it was reasonable for the trial judge to decline to reconsider a pretrial ruling by a different judge.

2017De novo review is appropriate in such circumstances "because the outcome of a Frye holding transcends individual cases such that applying less than a de novo standard could lead to inconsistent treatment of similarly situated claims." State v. Shively, 268 Kan. 573, 576 , 999 P.2d 952 (2000). 30 The State, on the other hand, contends that the abuse of discretion standard is appropriate because the actual question presented is whether it was reasonable for the trial judge to decline to reconsider a pretrial ruling by a different judge.

22003–2017
State v. Graham green
kan · 2003
2 sentences

2008The Frye test requires that the basis of an expert’s opinion “be shown to be generally accepted as reliable within the expert’s particular scientific field.” Graham, 275 Kan. 176 , Syl. ¶ 4.

2008The Frye test requires that the basis of an expert’s opinion “be shown to be generally accepted as reliable within the expert’s particular scientific field.” Graham, 275 Kan. 176 , Syl. ¶ 4.

22008–2013
State v. Warden green
kan · 1995
2 sentences

2003In Shively, 268 Kan. at 575-76 , we further stated: “The general acceptance test of Frye governs the admissibility of expert scientific evidence in Kansas in those situations wherein such a test or standard is required. [Citation omitted.] As explained in State v. Warden, 257 Kan. 94, 108 , 891 P.2d 1074 (1995): ‘The general rule enunciated in Frye prohibits expert testimony concerning a scientific principle or discovery unless the principle is “sufficiently established to have gained general acceptance in the particular field in which it belongs.” Frye, 293 F. at 1014 .

2003In Shively, 268 Kan. at 575-76 , we further stated: “The general acceptance test of Frye governs the admissibility of expert scientific evidence in Kansas in those situations wherein such a test or standard is required. [Citation omitted.] As explained in State v. Warden, 257 Kan. 94, 108 , 891 P.2d 1074 (1995): ‘The general rule enunciated in Frye prohibits expert testimony concerning a scientific principle or discovery unless the principle is “sufficiently established to have gained general acceptance in the particular field in which it belongs.” Frye, 293 F. at 1014 .

22000–2003
Tice v. Richardson green
kanctapp · 1982
2 sentences

1985App. 2d 509 , 644 P.2d 490 (1982), the Court of Appeals, using the Frye test, held that the human leucocyte antigen test is sufficiently established to have gained general acceptance in the particular scientific field to which it belongs as a reliable test to prove paternity.

1985App. 2d 509 , 644 P.2d 490 (1982), the Court of Appeals, using the Frye test, held that the human leucocyte antigen test is sufficiently established to have gained general acceptance in the particular scientific field to which it belongs as a reliable test to prove paternity.

21985–2000
United States v. Bruno green
paed · 1971
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
State v. Stout green
mo · 1972
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
State v. Linn green
idaho · 1969
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
People v. Williams green
calappdeptsuper · 1958
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
People v. Morse green
mich · 1949
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
People v. Alston neutral
nysupct · 1974
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
Brooke v. People green
colo · 1959
2 sentences

1981The Frye test has been utilized by courts in their consideration of the admissibility of paraffin tests (Brooke v. People, 139 Colo. 388 , 339 P.2d 993 [1959]); medical testimony regarding the cause of birth defects (Puhl v. Milwaukee Automobile Ins.

1981The Frye test has been utilized by courts in their consideration of the admissibility of paraffin tests (Brooke v. People, 139 Colo. 388 , 339 P.2d 993 [1959]); medical testimony regarding the cause of birth defects (Puhl v. Milwaukee Automobile Ins.

21981–1981
People v. Kelly yellow
cal · 1976
2 sentences

1981In People v. Kelly, 17 Cal. 3d 24, 31-32 , 130 Cal. Rptr. 144 , 549 P.2d 1240 (1976), the California Supreme Court points out the desirability of the Frye test in the following language: “Frye was deliberately intended to interpose a substantial obstacle to the unrestrained admission of evidence based upon new scientific principles. . . .

1981In People v. Kelly, 17 Cal. 3d 24, 31-32 , 130 Cal. Rptr. 144 , 549 P.2d 1240 (1976), the California Supreme Court points out the desirability of the Frye test in the following language: “Frye was deliberately intended to interpose a substantial obstacle to the unrestrained admission of evidence based upon new scientific principles. . . .

21981–1981
Puhl v. Milwaukee Automobile Insurance red
wis · 1959
2 sentences

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

1981Co., 8 Wis. 2d 343 , 99 N.W.2d 163 [1959]); breath analysis devices designed to test for intoxication (People v. Morse, 325 Mich. 270 , 38 N.W.2d 322 [1949]); truth serum injections (State v. Linn, 93 Idaho 430 , 462 P.2d 729 [1969]); blood tests (People v. Alston, 79 Misc. 2d 1077 , 362 N.Y.S.2d 356 [1974]); neutron activation analysis (State v. Stout, 478 S.W. 368 [Mo. 1972]); Nalline tests for detection of narcotics use (People v. Williams, 164 Cal. App. 2d Supp. 858 , 331 P.2d 251 [1958]); ink identification tests (United States v. Bruno, 333 F. Supp. 570 [E.D.

21981–1981
In re Care & Treatment of Cone green
kan · 2019
12020–2020
Martinez v. MILBURN ENTERPRISES, INC. green
kan · 2010
12013–2013
In Re McKenna neutral
kan · 1991
12013–2013
In Re the Commitment of R.S. green
nj · 2002
12013–2013
State v. Frye neutral
kanctapp · 2010
12012–2012
State v. Brown green
kan · 1999
12006–2006
United States Ex Rel. Green v. Washington green
ilnd · 1996
12006–2006
Commonwealth v. Bartolacci green
pasuperct · 1991
12003–2003
State v. Price green
kanctapp · 2002
12003–2003
State v. Ritt green
minn · 1999
12002–2002
People v. Mendoza green
cal · 2000
12000–2000
State Ex Rel. Hausner v. Blackman green
kan · 1983
12000–2000
People v. McDonald green
cal · 1984
12000–2000
Lust ex rel. Lust v. Merrell Dow Pharmaceuticals, Inc. green
ca9 · 1996
12000–2000
State v. Fuller green
kanctapp · 1990
12000–2000
Logerquist v. McVey green
ariz · 2000
12000–2000
State v. Dykes green
kan · 1993
11997–1997
State v. Colbert green
kan · 1995
11997–1997
State v. Barker green
kan · 1993
11995–1995
State v. Tran green
kan · 1993
11995–1995
People v. Webb neutral
nycountyct · 1993
11995–1995
Department of Social Services ex rel. Jenny S. v. Mark S. neutral
nycfamct · 1992
11995–1995

Statutes the citing opinions construe

KS § K.S.A. § 60-456 (21) KS § K.S.A. § 20-3018 (9) KS § K.S.A. § 21-3401 (8) KS § K.S.A. § 21-3502 (7) KS § K.S.A. § 60-404 (7) KS § K.S.A. § 21-3403 (6) KS § K.S.A. § 22-3601 (6) KS § K.S.A. § 22-3602 (6) KS § K.S.A. § 60-401 (6) KS § K.S.A. § 60-455 (6) KS § K.S.A. § 21-3421 (5) KS § K.S.A. § 8-1567 (5)

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

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 32 (1984–2017) CO 31 (1981–2021) MN 29 (1980–2026) CT 29 (1984–2005) MS 25 (1990–2008) NE 25 (1992–2017) AK 23 (1983–2019) DC 23 (1979–2026) MI 22 (1977–2024) OH 20 (1975–2023) VA 17 (1988–2010) IN 17 (1984–2023) SD 15 (1985–2026) WV 15 (1980–2026) DE 10 (1985–2025) WI 10 (1981–2021) KY 10 (1991–2015) NM 10 (1993–2016) ID 10 (1984–2013) TN 10 (1986–2014) GA 9 (1982–2020) NH 9 (1992–2004) AR 8 (1989–1996) UT 8 (1980–2019) IA 8 (1986–2025) OR 7 (1984–2024) RI 7 (1985–2020) MT 7 (1991–2026) LA 7 (1982–2018) HI 7 (1992–2026) OK 6 (1994–2025) VT 6 (1993–2009) WY 6 (1983–2025) NC 6 (1984–2004) 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.

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