Massachusetts
How Daubert v. Merrell Dow Pharmaceuticals, Inc. applies in Massachusetts: state-specific rules, key cases, and bar exam notes for Evidence.
Massachusetts follows a version of the Daubert standard through its own Evidence Rule 702. This rule requires that expert testimony be both relevant and reliable, similar to the federal standard, with additional scrutiny on whether the method used is generally accepted in the relevant field.
Under Massachusetts Rule of Evidence 702, expert testimony must assist the trier of fact in understanding the evidence or determining a fact in issue, and the witness must be qualified as an expert by knowledge, skill, experience, training, or education.
Expert testimony concerning mental health was deemed admissible based on the reliability of the methods used.
Established the standard that scientific evidence must be generally accepted in its field, preceding the adoption of Daubert principles.
Clarified the applicability of expert testimony standards in employment discrimination cases under Massachusetts law.
Massachusetts' approach under Rule 702 closely mirrors the Daubert standard, requiring both relevance and reliability of expert testimony. However, some Massachusetts courts may put greater emphasis on the general acceptance of the methodology in various scientific communities compared to certain federal applications.
Understanding the application of the Daubert standard in Massachusetts is critical for the bar exam, particularly in property and torts questions dealing with expert testimony.