In People v. Miller, 173 Ill. 2d 167, 670 N.E.2d 721, 731 n.3, 219 Ill. Dec. 43 (Ill. 1996), the Illinois Supreme Court stated that Frye claims are to be reviewed for an abuse of discretion. Miller, 670 N.E.2d at 731-32. Despite this statement, the court proceeded to consider scientific journals outside the record. Justice McMorrow criticized the majority for setting forth the abuse of discretion standard but then not applying it. He argued that "the all-encompassing abuse of discretion standard . . . does not permit a reviewing court to adequately address the legal issues" in these cases and advocated a "mixed standard of review" in which trial court decisions concerning the expert's qualifications and his testimony's relevance be reviewed for abuse of discretion but decisions regarding whether a technique has achieved general acceptance be reviewed de novo. Id. at 739. He reasoned that a theory or technique's general acceptance in the scientific community "transcends any particular dispute" and "application of less than a de novo standard of review to an issue which transcends individual cases invariably leads to inconsistent treatment of similarly situated claims." Id.