Federal Rule of Evidence 702 provides the starting point when considering the admissibility of expert testimony:
A witness who is qualified as an expert by knowledge, skill, experience, training, or education may testify in the form of an opinion or otherwise if: (a) the expert’s scientific, technical, or other specialized knowledge will help the trier of fact to understand the evidence or to determine a fact in issue; (b) the testimony is based on sufficient facts or data; (c) the testimony is the product of reliable principles and methods; and (d) the expert has reliably applied the principles and methods to the facts of the case.
Fed. R. Evid. 702. In Kumho Tire Co., Ltd. v. Carmichael, 526 U.S. 137 (1999) and Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993), the Supreme Court held that trial courts have a gatekeeping function designed to test expert evidence for relevance and reliability. In performing this function, the Court applies a “rigorous three-part inquiry” by considering whether (1) the expert is qualified to testify competently about the issues at hand, (2) the expert’s methodology is sufficiently reliable, and (3) the expert’s testimony helps the trier of fact understand the evidence or determine a factual issue. United States v. Frazier, 387 F.3d 1244, 1260 (11th Cir. 2004). “While there is inevitably some overlap among the basic requirements—qualification, reliability, and helpfulness—they remain distinct concepts and the courts must take care not to conflate them.” Id.
For a further discussion concerning the admissibility of expert testimony, please visit the following blog post: Under Florida Law, What is the Standard for Admissibility of Expert Testimony?
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