Frye was facing charges of a second-degree murder. As the defendant in the case, his lawyer sought to bring on board an expert to testify on a deception test for systolic blood pressure. The test was to be performed on Frye and was to show if he lied before the court or spoke the truth. It was because; an individual’s blood pressure usually rises when they lie. However, the trial court rejected the expert’s testimony. As such Fryer was convicted of second-degree murder and he appealed. Important to note is that Fryer had earlier confessed to be the person behind the murder but was later to recant his admissions (Giannelli, 1980).
Issues
The sole issue in the appeal was the rejection of the deception test by the trial court. The court described the mode of operation of the lie detector. As such, details of how an individual’s blood pressure changes whenever they speak a lie based on the change in their emotions came to the fore. Fryer then argued how systolic blood pressure would rise in a predictive curve whenever an individual subjected to it became deceptive and afraid of their fear being detected. The court characterized Fryer’s information as a theory arguing that truth is often spontaneous. Therefore it comes without an individual engaging a conscious effort. However, when one lies, they require a deliberate move which can be reflected in the blood pressure. But then there were no previous cases for use to guide the court. Hence, the court was left with the option to decide on the admissibility of the test for use in court. The court ruled that the systolic blood pressure test had not amassed enough scientific approval among the professionals belonging to the psychological or physiological field so that it can be justifiable allowed for admission to a court of law. Hence, the court ruled against the admission of the systolic test and Fryer’s conviction affirmed.
Delegate your assignment to our experts and they will do the rest.
Rule of law
The rule concerning expert opinions in court is that an expert's opinion or that of a skilled witness is only admissible in court as evidence in cases where the matter of inquest is in a manner that inexperienced individuals are not likely to form a correct judgment concerning it. However, for cases that require an art, science, or trade, there is a need to acquire experience or knowledge on the same. In a case where the questions involved lie outside the common experience or knowledge then a witness skilled in the matter has a valid opinion admissible to court as evidence.
Findings
Based on the rule of law, the court, therefore, found that the systolic tests were not admissible in the court. This is because the deceptive test had not gained the scientific credit or a standing. As such, it would not have provided a justifiable reason for the courts to admit it for use by an expert witness in providing testimony that could be deduced from its discovery, experiment or use so far. Consequently, they ruled it out and affirmed the judgment that Fyer was guilty as charged for second-degree murder.
Importance of the Case and how it affects the Practice Today
Fyer vs. the state is a crucial case to look upon today. Over the past decades, the use of Systolic lie detectors has always been inadmissible in the court of law as evidence. But over 1970’s and 80’s, the use of Systolic lie detector in courts have gained respect gradually across the scientific community (Hyatt, 2013). Physiological and psychological scholars have indeed recognized the accuracy of systolic tests prompting some courts to begin admitting their use in certain circumstance although in a limited way for both civil and criminal cases. After the case of Frye vs. the state, the decision reigned supreme for over 70 years. Before Fryer’s case, in 1920 a Columbia court also rejected the use of the technology in court in a case against William Moulton Marston (Hyatt, 2013).
However, in recent years things have changed. For the US intelligence community, the Systolic lie detector has become an important part of their operation. They have used the system to identify criminals and even spies whenever direct evidence is not available. Due to its measure of an individual’s physiological process, its advocates have claimed that it has a space in modern science. In 1993, the case of Daubert the Supreme Court provided an outline of the current of admissibility of any scientific evidence in the federal courts (Germany, 2014). It later became useful in codifying the federal evidence rule in 2000. T5he rule required the court judge to act as the goalkeeper and assess the reliability of the basis of proffering scientific evidence in court.
Since 2001, the US has become more open to the technology and its ability to detect any evildoer. This follows the attack of terrorists that has increasingly become rampant today. Many courts in the US and even outside its territories today accept the use of lie detectors now referred to as a polygraph. However, some do so with a few discretions. In Massachusetts, they allow the use of polygraphs but with some discretion. The technology has also resulted in two main constitutional issues. Germany, (2014) points out that there is a claim that denying admissibility of polygraphs in court contravenes the sixth amendment right to present evidence in a court of law. Also, there is a claim that refusing to admit polygraphs in courts contravenes the fifth as well as the fourteenth amendment that enshrines a defendant’s right to due process.
Albeit with a few limitations, the lie detector has today become widely appreciated in its role in the justice system especially when the evidence is completely lacking. More research needs to be done to strengthen its reliability in the courts.
References
Giannelli, P. C. (1980). The admissibility of novel scientific evidence: Frye v. United States, a half-century later. Columbia Law Review , 80 (6), 1197-1250.
Germany, A. V. F. (2014). Human Rights and Legal Limits on the Use of Deception Detection Methods. European Psychologist , 19 (3), 221-223.
Hyatt, S. K. (2013). Developments in the Law of Scientific Evidence: The Admissibility of Polygraph Evidence. Journal of the National Association of Administrative Law Judiciary , 18 (2), 1.
