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Marsh v. Valyou

Florida Supreme Court
977 So. 2d 543 (Fla. 2007)


Jill Marsh (plaintiff) was in a series of car accidents. Marsh filed a negligence suit against Robert Valyou, Avis Rent-A-Car, and others involved in the car accidents (defendants). Marsh alleged that the car accidents had caused her to suffer from fibromyalgia. Marsh sought to introduce expert testimony to that effect. Marsh’s expert witnesses based their conclusions regarding the link between trauma and fibromyalgia on traditional scientific methods and principles. However, the trial court excluded Marsh’s proffered expert testimony as unreliable based on Frye v. United States, 293 F. 1013 (D.C. Cir. 1923), which required that an expert’s scientific method be generally accepted in the relevant scientific community. Specifically, the trial court held that the opinion that trauma could cause fibromyalgia had not been generally accepted in the scientific community. The trial court granted summary judgment for the defendants. Marsh appealed.

Rule of Law


Holding and Reasoning (Per curiam)

Concurrence (Anstead, J.)

Dissent (Cantero, J.)

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