Barriers against expert psychological evidence were lifted by recent legal decisions in England and the United States. In England the Turner rule still excludes testimony that deals with matters deemed by the judge to lie within the "common knowledge and experience" of a jury, but due to the decision in R. v. Sally Lorraine Emery (and Another) (1993), the rule is no longer interpreted to exclude all psychological and psychiatric evidence that relates to nonclinical psychological phenomena. In the United States, the confusion that has existed for many years over the Frye test and the Federal Rules of Evidence was dispelled in 1993. The U.S. Supreme Court decided in Daubert v. Merrell Dow Pharmaceuticals (1993) that the Frye test was superseded by the Federal Rules of Evidence. The Frye test is effectively dead, and expert testimony will no longer be ruled inadmissible on the grounds that it has not "gained general acceptance in the particular field in which it belongs." Expert evidence is now admissible, provided that it is based on "scientific knowledge," which is assumed to guarantee a standard of evidential reliability or trustworthiness, and that it is also relevant, which according to the Federal Rules of Evidence means that it has a "tendency to make the existence of any fact that is of consequence to the determination of the action more probable or less probable than it would be without the evidence." It has always been up to the courts to decide whether or not proposed expert evidence was relevant; U.S. courts must now also decide whether or not the evidence is based on "scientific knowledge" and is therefore reliable. 23 references