California
How Daubert v. Merrell Dow Pharmaceuticals, Inc. applies in California: state-specific rules, key cases, and bar exam notes for Evidence.
California follows a similar admissibility standard for expert testimony as articulated in Daubert, primarily through the California Evidence Code. However, California courts apply a more flexible approach, emphasizing the reliability and relevance of the evidence, often looking to the Frye standard as well.
Under California Evidence Code § 720, an expert's testimony is admissible if it meets the standard of general acceptance within the relevant scientific community; however, California courts also recognize the need for relevant and reliable expert opinions as established in Daubert.
The California Court of Appeal emphasized that trial courts must ensure expert testimony is based on generally accepted principles and methodologies within the relevant scientific community.
In this case, the California Supreme Court reinforced the trial court's gatekeeping role, indicating that the court must ensure expert testimony is both relevant and reliable.
The court ruled that expert testimony must be grounded in accepted knowledge or experience, emphasizing the necessity of scientific validity and relevance.
California’s approach to expert testimony retains elements of the Frye standard, focusing on general acceptance, yet acknowledges the Daubert requirements of reliability and relevance. This creates a dual standard where both scientific and non-scientific bases for expert testimony may be considered.
Understanding the dynamics between Daubert and California's Evidence Code is critical for the California bar exam, especially regarding the admissibility of expert testimony and the role of trial judges as gatekeepers.