Frye v. United States

For years, lie detector tests were inadmissible as evidence in virtually all courts. However, in the 1970s and 1980s, as the practice of lie detection gradually gained respect in the scientific community, some courts began to admit the evidence in certain situations and for limited purposes in both criminal and civil trials. However, courts in most states continue to prohibit any and all forms of polygraph evidence.

On the topic of the admission of expert testimony, the formula in the Frye decision reigned supreme for 70 years. This was especially true in the early 1970s when, just before the Federal Rules of Evidence were adopted, courts across the country began to cite Frye. The formula for admissibility of scientific evidence created by Frye--whether the practice or procedure was generally accepted in the scientific community--eventually proved too difficult for courts to manage as the scientific community expanded and progressed. In Daubert v. Merrell Dow Pharmaceuticals, Inc. (1993) the High Court held that admissibility of expert testimony should be controlled by Rule 702 of the Federal Rules of Evidence, and that it need not be generally accepted in the scientific community to be admitted; rather, expert testimony should be admitted if it rests on a reliable scientific foundation and is relevant to the issue at hand.