Maryland
How Daubert v. Merrell Dow Pharmaceuticals, Inc. applies in Maryland: state-specific rules, key cases, and bar exam notes for Evidence.
Maryland follows the Daubert standard for expert testimony, requiring that such evidence be both relevant and reliable. The Maryland Courts have adopted the criteria outlined in Daubert as a guide to assess the admissibility of expert testimony.
In Maryland, the admissibility of expert evidence is governed by Md. Rule 5-702, which aligns with the Daubert standard emphasizing reliability, relevance, and the application of specialized knowledge to assist the trier of fact.
The Maryland Court of Appeals ruled that expert testimony on DNA analysis must meet the Daubert standard, emphasizing the reliability of the methodology used.
The court determined that the expert's methodology must be scrutinized under the Daubert factors, further clarifying the application of scientific evidence.
This case established that not all expert testimony qualifies under Daubert; the proponent must show the scientific basis and relevance of the evidence.
Like the federal standard under Daubert, Maryland's rule requires that expert testimony is not only relevant but also derived from a reliable methodology. However, Maryland courts may have slightly more flexibility in the application of these standards compared to some federal jurisdictions.
Competence in the Daubert standard and its application in Maryland is often tested on the Maryland bar exam, highlighting the need to distinguish between admissibility criteria.