Frye v. United States, 293 F. 1013 (D.C. Cir. 1923)
Frye v. United States is a landmark decision in evidence law that set the foundational standard for admitting novel scientific techniques into courtrooms: the general acceptance test.
Is expert testimony based on a novel scientific technique—the systolic blood pressure deception (lie detector) test—admissible when the technique has not yet gained general acceptance in the relevant scientific community?
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." Novel scientific evidence is inadmissible absent such general acceptance.
No. The systolic blood pressure deception test had not achieved general acceptance among physiological and psychological authorities, so expert testimony based on it was inadmissible. The conviction was affirmed.
Frye established the general acceptance test for admitting novel scientific evidence, a standard that governed federal and many state courts for most of the twentieth century. The case underscores the judiciary's gatekeeping role and its concern that juries might be misled by the aura of science absent a demonstrated consensus on reliability. Even after the Supreme Court adopted a different reliability framework in Daubert under Federal Rule of Evidence 702, many states continue to apply Frye or a Frye-like test (e.g., New York's Frye standard; California's Kelly/Frye via People v. Kelly; Maryland's Reed/Frye), making the case essential for understanding the variation in evidentiary standards across jurisdictions. For law students, Frye is critical for mastering expert evidence doctrine, comparing Frye to Daubert and Kumho Tire standards, and appreciating how courts balance innovation with institutional caution. It also remains relevant to recurring controversies such as polygraph evidence, forensic techniques, and other emerging methodologies where the degree of professional consensus is hotly contested.