FRYE CASE

3/18/2022

AcerSUBMITTED TO: UNARCE, LEIA GRACE ELAINE

SUBMITTED BY:
Bernard Lutwachen Jr.
Angelica Winta
Rosabel Gayuchan
Martha Latogan
Tishagay Layagan
Shiela Mae Waglison
 I. INTRODUCTION
Supreme Court consistently defines custodial investigation as the stage
where an investigation is no longer a general inquiry into an unsolved crime but
has begun to focus on a particular suspect taken into custody by the police or
other law enforcement agents who carry out a process of interrogation that lends
itself to elicit incriminating statements. It involves questioning initiated by law
enforcement officers after a person has been taken into custody or deprived of
freedom of action in any significant way.
Defining rights, it is the common claim of people that every civilized
society recognized as essential claims for their development and which are
therefore enforced by the state. Every one of us has our rights as a human that
can’t be taken away from us. When a certain suspect is being arrested, they still
possess a right. Any person under investigation for the commission of an
offence shall have the right to be informed of his right to remain silent and to
have competent and independent counsel preferably of his own choice. It is the
duty of a police officer to conduct an investigation where during the custodial
investigation the investigating officer or investigator of the case must inform the
arrested person about his/her rights in a language understood by the arrested
person. Failure to this, all the evidence or confessions of the suspect will be
inadmissible as evidence in any proceedings. Informing the rights of the
arrested person will lead to a successful and saturate process in filing a case
against the perpetrator. Also, all the extra-judicial confessions gathered from the
suspect will be admissible as evidence in any proceedings.
If the constitutional rights of a person under custodial investigation are
violated, there are corresponding penal and civil sanctions, as well as
compensation to and rehabilitation of victims of torture or similar practices, and
their families. These sanctions are provided for in different statutes, i.e., civil
sanctions, in the form of damages, covered by Article 32 of the New Civil
Code, and penal sanctions covered by the penal clause of Republic Act No.
7438, where a fine, penalty, or both, may be imposed upon an erring officer.
 II. SUMMARY OF THE CASE
The landmark case Frye v. United States is associated with the general-
acceptance standard for admissibility of scientific evidenced. R. W. Brown,
Well Known Colored Doctor, Shot Through Temple,” announced the
Washington, D.C., Evening Star on November 28, 1920.1 Washingtonians were
shocked by the Saturday night slaying of the president of the National Benefit
Life Insurance Company by an unknown assailant. Dr. Brown, a widower with
two daughters, had received four calls that day, and his house guest, Dr. Julian
Dabney Jackson from Virginia, admitted a man late in the evening. Dr. Jackson
described him as “being of light brown skin, about twenty-four or twenty-five
years old, weighing about 135 pounds, and wore a dark brown suit” (Ref. 1, p
1). Dr. Brown and the man conversed and then Dr. Jackson heard four gunshots.
Although there was no theory of motive, a .45-caliber revolver was left on the
floor near the victim, and fingerprints were found on the bricks outside the
house. A few months earlier, Dr. Brown had received a threatening letter,
instructing him to leave money inside Union Station. After Dr. Brown called the
police, a detective left the money, but no one claimed it.
The victim's family offered a $1,000 reward for the capture of the shooter,
but nearly a year elapsed before there was a break in the case. The August 23,
1921, Evening Star carried the headline, “James A. Frye Tells Police Shooting
Was Done in Self-defense After Doctor Struck Him.”3 Mr. Frye was caught
forging a soldier's name to a government compensation check and then admitted
to the robbery of a watch and a diamond ring from a salesman from Indianapolis
whose taxi had broken down. The Page 5 news story suggested that
incriminating information led detectives to question Mr. Frye about Dr. Brown's
murder. The suspect apparently volunteered that he had shot the doctor after a
disagreement: The prisoner told Inspector Grant and the detectives that he went
to the physician's office for a prescription. He had only one dollar, he said, and
the physician said two dollars was his price. Dr. Brown, he said, declined to
accept his pistol as collateral for the extra dollar.
An auspicious set of circumstances led to Frye v. United States: two
attorneys were desperate for a way to extricate Mr. Frye from a possible death
penalty, and a psychologist was testing a physiologic lie detector. The
psychologist, Dr. William Moulton Marston, having discovered (he did not like
the term invented) the systolic blood pressure deception test in 1915, was eager
to promote the test. A recent faculty member at American University in
Washington, D.C., According to Marston,6 Mr. Frye's lawyers came to him and
he agreed to test the defendant gratis. The court did not accept the polygraph ad
as evidence. In the court's opinion, the systolic blood pressure deception test had
not gained enough "standing and scientific recognition among physiological and
psychological authorities" to justify its admission as evidence in courts of law.
The court approved of the exclusion of the deception test, and Frye's conviction
was affirmed.
 III. DOCUMENTATION CONCERNING THE CASE

Figure 1 Dr. William Marston (seated at right) check James Frye's pulse and blood pressure in this 1926 simulation of the
Systolic Blood Pressure Deception Test that he had administered to Mr. Frye before his murder trial in 1922.
 IV. INDIVIDUAL REACTION

Angelica Winta
Evidences are crucial things that will prove or disprove certain facts
which shows whether something is true or not. Evidences are not just basically
shown to a trial but instead, it needs a scientific recognition from an authority
from a certain field which that evidence belongs to.
In the case of Mr. Frye, despite of him having a testimonial evidence
which would prove whether he is guilty or not, he was still proclaimed guilty of
the crime murder. His testimonial evidence was excluded because during the
time of his trial, he requested an attempted to call an expert witness to testify
that Appellant had taken a systolic blood pressure deception test, and to further
testify as to the results of the test. The deception test of Mr. Frye was excluded
since according to the court, despite of it having a scientific basis, it is hard to
define the test. His requested deception test or testimonial evidence would have
been considered admissible if he has sought recognition from authorities from
the field of his evidence. But since he didn't, it was excluded by the law.
Evidence should have a scientific recognition from an authority from the
field of a certain evidence for it to be recognize as a valid evidence. As future
enforcer, I can use the knowledge I have gained by, in the future when I am
faced with a situation like this, I already know what to do. I already know that
evidences which I will present in court should have already been recognize by
authorities from the field of my evidence before it will be presented in court.
 Shiela Mae Waglison
After reading the case for I think how many times because to be honest,
the case is somehow intriguing and further research is needed. The case
provided great detail of the science behind how the lie detector test functioned.
But it also shows how the trial court refused to allow the expert’s testimony,
where the Supreme Court upheld the lower court’s decision.
At first, I questioned why did the lower court excluded the expert
testimony regarding the systolic blood pressure deception test. I thought it was
unjustified to just denied the testimony but I was enlightened on the reason why
it was happened. I’ve learned that the admissibility of the testimony or evidence
did not meet he requirement that such evidence be sufficiently established to
have gained general acceptance in the particular field in which it belongs, that is
why the test results were properly excluded by the lower court.
Having prior knowledge about the case, it really helps us appreciate more
our subject matter. The case plays an important role to us as a future law
enforcer for it imparts a great knowledge and idea whenever we encounter
situation as that of Frye's case. This will not only help us on our study today but
will surely help us on our profession someday.
 Rosabel Gayuchan
The case of Mr. Frye is an interesting. I discuss the admissibly of the
systolic blood pressure deception test as evidence. The Scientific evidence is
most often presented in court by an expert witness testifying on expert opinions.
It also includes expert testimony that goes beyond science. But in the case of
Mr. Frye, the court deemed the results inadmissible.
After having enough knowledge about the case, I was able to understand
that the court decide if the questioned procedure, technique or principle are
generally accepted by the scientific community.
This case is important to us as a future law enforcer for it shows the
importance of rights of an accused and knowledge on the admissibility of an
evidence. This knowledge I’ve learned from this case remain as I continue to
achieve my dream. I’ll make sure that it will not only help me in the near future
but also help our country.
 Tishagay Layagan
The case of Mr. Frye is quite complicated but somewhat interesting as
this issue became controversial during their time. It made me conduct research
about the case and its background. After reading it, I've understood the
relevance of studying it, being a criminology student aiming to be part of police
someday. I've learned the importance of custodial investigation and the rules of
admissibility of expert witness, and even the rights of the accused.
At first, I see the decision of the Court as unfair and unjust in the side of
Mr. Frye, because they didn't consider the expert witness regarding the systolic
blood pressure deception test and the reason that he didn't know his rights
during the confession. However, I've learned that although science has facts in
it, it is still useless without sufficiently establishing it. Also, it must be generally
accepted as reliable in the relevant scientific community. This was the reason of
the court for considering the systolic blood pressure deception test as
inadmissible. The decision of the Court was good and fair for the victim. We
cannot just free the convict by just a lie detector device which is not fully
established, considering the situation that the aggrieved party is thirsty of
justice.
The concept of this case is helpful, as it is necessary to know. This also
has great contribution to the court because Frye standards for admissibility was
established and was widely adopted and applied to most courts in the world.
Reading the whole story of Frye Case challenged me that as a criminology
student, it is a must to learn everything that is related to my future profession so
that I will have something to apply someday. I will be part of the police work,
and I will be part of obtaining justice for the victims by doing excellent work
and accurate job as that of Frye's case.
 Martha Latogan
Mister Frye was proven guilty in committing murder. Despite having the
testimonial evidence, he was proclaimed guilty for he was not allowed to
present testimonial evidence. In the case of Mr. Frye, his testimonial evidence
did not meet the requirement that it must gain scientific recognition by
psychological and physiological authorities.
In the case of mister Frye, his testimonial evidence was not allowed since
during the time of his trial, he attempted to call an expert witness to testify that
Appellant had taken a systolic blood pressure deception test, and to further
testify as to the results of the test. The court excluded his testimonial evidence
since according to the court, although the deception test has a scientific basis,
the test was still in the blurred realm between experimental science and
demonstrated science meaning, they cannot define the test easily. The requested
deception test of Mister Frye would have been considered admissible if he has
sought an expert's testimony before his trial. However, he did not. Thus, his
requested deception test is considered inadmissible.
From the case that I have read, I came to realize that evidences that would
be used in a certain trial should undergo a process like it should have gain a
scientific recognition coming from an authority from the field of where that
certain evidence belongs to. As a future enforcer, I can use this gained
knowledge by, I already know that an evidence should undergo a certain
process so when in the future, I can use this to my advantage.
V. DOCUMENATION WHILE DOING THE CASE
VI. STEPS ON HOW DID WE FINISH THE PAPER

 In creating our Group, we actually didn’t choose some of our

members to be part of the group, they ask to join. And since we
knew each other, we decided to be grouped as one.
 Next thing we did is we created a Group chat that serves portal of
communication since we are not living in the same place.
 In collecting data, we use the internet to gather information. We
decided that each member will search and understand the case for
us to be able to share knowledge and ideas.
 Throughout the activity, one of the challenges that we encounter as
a group is the lack of unity. Some members we’re able to send their
answers on time while others are not. It is somehow true that
student nowadays is accustomed to the thing “last minute”. It is
also become a challenge for me as a collector of our answers for it
is not easy to compile and edit answers for just a minute.
 Nonetheless, we were able to finish the activity by communicating,
reminding each and everyone of their responsibility as a member
and as a student.