Missouri
How Daubert v. Merrell Dow Pharmaceuticals, Inc. applies in Missouri: state-specific rules, key cases, and bar exam notes for Evidence.
Missouri courts have adopted a standard consistent with Daubert, emphasizing the reliability and relevance of expert testimony. The Missouri Supreme Court follows the Frye standard but has increasingly incorporated Daubert's principles into their evaluations of expert evidence.
Under Missouri law, expert testimony must be based on scientifically valid reasoning and methods. The court evaluates factors such as testing, error rates, peer review, and acceptance in the relevant scientific community.
The Missouri Court of Appeals reiterated that expert testimony must meet the criteria of reliability, paralleling the Daubert standard.
The court ruled that the expert's methods were not generally accepted in the scientific community, thus failing to meet the Daubert standard.
This case highlighted the importance of relevance and reliability in expert testimony, reinforcing Missouri's alignment with Daubert principles.
Missouri's approach is evolving towards a more Daubert-like standard but still retains elements of Frye. Federal courts generally apply a strict Daubert framework, emphasizing the judge's gatekeeping role more firmly than Missouri courts have traditionally done.
Understanding the application of Daubert in Missouri is crucial for the bar exam, particularly for questions related to the admissibility of expert testimony.