Is ''General Acceptance'' Same As ''Universal Acceptance'' ?
In Frye. Donaldson v. Central Illinois Public Service Co., 199 Ill. 2d 63, 76-77, 767 N.E.2d 314, 262 Ill. Dec. 854 (2002), the court approved the extrapolation method to link the cause of plaintiffs' rare cancer, neuroblastoma, to the deleterious effects of coal tar, because the plaintiffs relied on scientific literature discussing similar, yet not identical, scientific studies and theories. Donaldson, 199 Ill. 2d at 85, 88.
In Donaldson, the court provides a clear explanation of what "general acceptance" may or may not include. the court states that "'general acceptance' does not concern the ultimate conclusion," but the "underlying methodology," and that "if the underlying method used to generate an expert's opinion is reasonably relied upon by the experts in the field, the fact finder may consider the opinion." Donaldson, 199 Ill. 2d at 77.
The court also explained that although general acceptance "does not mean 'universal' acceptance," and "does not require unanimity, consensus, or even a majority of experts," the expert must still utilize "generally accepted methodology to develop the conclusion," and "a technique is not 'generally accepted' if it is experimental or of dubious validity." Donaldson, 199 Ill.2d at 77-78.
After deciding that the method of extrapolation relied upon by the plaintiffs passed the Frye test, the Donaldson court reiterated that the methodology must be relied upon by experts in that particular field. Donaldson, 199 Ill. 2d at 87-88.