Frye v. United States,293 F.2d 1013 (D.C. Cir. 1923), held that for new and novel scientific evidence to be admissible, it must be generally accepted within its particular field. Under Frye, all other expert evidence is generally admitted without the trial judge first assessing its reliability before submitting it to the jury. Frye was adopted by the Florida Supreme Court in Bundy v. State,471 So. 2d 9 (Fla. 1985).

In Daubert v. Merrill Dow Pharmaceuticals, Inc.,509 U.S. 579 (1993), the U.S. Supreme Court held that the Federal Rules of Evidence, adopted in 1975, superseded Frye. Under Daubert, the trial judge must preliminarily determine the reliability of expert evidence by conducting an assessment of whether the expert’s reasoning or methodology is scientifically valid and can be applied to the facts at issue.