Florida Frye Standard Reaffirmed
Florida State Courts Reaffirms Frye Standard for Admissibility of Expert Testimony In a decision by the Florida Supreme Court in reversing the Fourth District Court of Appeals’ decision in DeLisle v. Crane Co., the Frye standard for admissibility of expert testimony has been reaffirmed in Florida state courts. The Court stated, “Frye relied on the scientific community to determine reliability whereas Daubert relied on the scientific savvy of trial judges to determine the significance of the methodology used…” DeLisle v. Crane Co. , 2018 Fla. LEXIS 1883, *1 . Historically, the Frye standard was followed in Florida state courts until 2013, when the Daubert standard was implemented and amended into the Florida Rules of Evidence Code. Daubert v. Merrell Dow Pharmaceuticals, Inc ., 509 U.S. 579 (1993). The Daubert standard provided for judges’ discretion to determine the reliability of expert testimony through detailed analysis of facts, data, p