The origin of the Daubert standard is the landmark case, Daubert v Merrell Dow Pharmaceuticals, Inc., the –U.S. — Ct. 2786, 125 L. Ed. 2d 469 where the court established a strict test regarding, not only the relevance, as established earlier in Frye, but also reliability. The court outlined a four-part standard to assist judges in executing their gate-keeping duty of ensuring that scientific experts did not bring into court “novel” or “junk science” testimonies as evidence. This standard borrows heavily from the Federal Rules of Evidence ratified by the Congress in 1975, particularly Rule 702. The federal rules allow a technical rather than a scientific qualification for the testimonies presented by origin-and-cause fire investigators. The Daubert factor administers a test to measure whether the technique or theory may be tested or refuted or whether it has been a subject of peer review or publication. It also measures error rate and acceptability within the relevant scientific community. This test is flexible. Therefore, a party does not need to prove all of its aspects for expert testimony to be admissible. However, Daubert alone is incredibly restrictive, as it only applies to scientific evidence. In 1999, the Supreme Court expanded the scope of its applicability to all other areas of expertise that are scientific or non-scientific in the landmark case, Kumho Tire Co. Ltd., v Patrick Carmichael, 526 U.S. 137 (1999). In view of the aforementioned precedents and statutes, it is pertinent to mention the significance of the NFPA 921 guidelines to fire investigation. So far, these are the only accepted codified scientific or procedural methods of conducting a fire investigation. Daubert stipulates that the expert testimony of a fire investigator should be in accordance with scientific standards and peer reviewed or published work. Therefore, the NFPA 921 guidelines play an immensely significant role in adjudicating the validity of expert witnesses, as well as of their testimonies. However, it is neither a code nor a required practice. Michigan Millers Mutual Insurance Co. v. Benfield, 140 F. 3d 915 (11th Cir. 1998) case Facts An insurance company denied a residential fire claim. During the trial, “the company’s expert testified that the fire originated on the top of the dining table where there were several clothes, papers, and other combustibles piled up next to an empty bottle of lamp oil” (Tuft 89). The expert stated that the only potential source for an accidental cause was the chandelier above the table. He had 30 years experience as an origin and cause investigator with a record of more than 5000 fires investigated during his career. His career experience included private investigation and a fire marshal at the City of Tampa. The court approved of his experience and qualified him as an expert capable of providing testimony as evidence. However, after he presented evidence on the methodologies he applied in coming up with the conclusions on the origin and cause of the fire, the court granted the insured party a motion to strike the expert’s testimony. Issue The issues included whether the Daubert rule applied to the prosecution’s expert testimony as it did not rely on “purely scientific principles” but on his skill, observations on the scene of the fire, and experience.