Grady v. Frito-Lay, Inc.

Summary

The Supreme Court of Pennsylvania held that Pennsylvania continues to apply the Frye general-acceptance test to the admissibility of novel scientific evidence. The Court concluded that the plaintiffs failed to establish that their expert's methodology was generally accepted in the relevant scientific field for determining whether Doritos remained too hard and sharp to be safely consumed. The Court therefore affirmed the exclusion of the expert testimony and reversed the Superior Court's order remanding the case for trial.

Holdings

1. Pennsylvania retains the Frye general-acceptance test for determining the admissibility of novel scientific evidence under Pennsylvania Rule of Evidence 702.
2. The Frye inquiry concerns whether the expert's methodology is generally accepted by scientists in the relevant field as a method for arriving at the conclusion the expert will offer; the proponent need not establish general acceptance of the expert's ultimate conclusion itself.
3. The proponent of expert scientific evidence bears the burden of establishing all requirements for admission under Pennsylvania Rule of Evidence 702, including satisfaction of Frye.
4. Whether a witness is qualified under Rule 702 and whether the witness's methodology satisfies Frye are distinct inquiries that must be separately developed and separately ruled upon.
5. The Superior Court erred by substituting its own assessment of Beroes's testimony for the trial court's determination without deciding whether the trial court abused its discretion.
6. The trial court properly excluded Beroes's testimony because plaintiffs failed to prove that his testing methodology was generally accepted by scientists in the relevant field for determining whether Doritos remained too hard and sharp to be safely eaten.

Questions Presented

1. Whether Pennsylvania should retain the Frye general-acceptance test rather than adopt the Daubert standard for evaluating scientific expert testimony.
2. Whether the proponent of scientific expert evidence must establish that the expert's methodology is generally accepted by scientists in the relevant field as a method for reaching the conclusion to be offered.
3. Whether the trial court abused its discretion by excluding Beroes's testimony under Frye.
4. Whether the Superior Court properly reversed the trial court without applying the abuse-of-discretion standard.

Disposition

reversed_and_remanded