In 1993, the U.S. Supreme Court handed down the decision of Daubert v. Merrell Dow Pharmaceuticals Inc., 509 U.S. 579 (1993). In holding that the previous "general acceptance test" articulated in Frye v. United States, 293 F. 1013, (D.C. Cir. 1923) was "incompatible with the Federal Rules and should not be applied in federal trials," Daubert, 509 U.S. at 589. The Supreme Court in Daubert set forth a new standard where "trial judges became the gatekeepers of expert testimony, responsible for independent screening of science and the reliability of expert witnesses." Roger C. Park et al., Evidence Law 539 (3d ed. 2011). The standards for judicial review and Daubert's application to non-scientific expert testimony were later clarified by the court in the cases of General Electric Co. v. Joiner, 522, U.S. 136 (1997) and Kumho Tire Co. v. Carmichael, 526 U.S. 137 (1999). Id. at 538-40.
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