The state of Iowa does not strictly follow the Daubert test for the admissibility of expert witness testimony, but instead the courts are strongly encouraged to consider the Daubert test when determining the admissibility of expert witness testimony. Frank v. GITS Manufacturing, 786 N.W.2d 519 (Iowa Ct. App. 2010). Specifically, the Daubert test is helpful for courts in “complex cases” when the court is “assessing the reliability of expert testimony.” Id. Courts in Iowa are to interpret the rules for the admissibility of expert testimony liberally. Id. The requirements for admitting expert testimony are: “(1) the evidence must be relevant, (2) the testimony must be in the form of ‘scientific, technical, or other specialized knowledge that will assist the trier of fact to understand the evidence or to determine a fact in issue’, and (3) the expert must be ‘qualified as an expert by knowledge, skill, experience, training, or education.” Id.
Is Daubert or Frye used for expert witness testimony admissibility in Iowa?
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