United States v. Semrau
United States Court of Appeals for the Sixth Circuit
693 F.3d 510 (6th Cir. 2012)
Dr. Lorne Semrau (defendant), charged with Medicare billing fraud, sought to introduce testimony from Dr. Steven Laken about a patented lie-detection test Laken administered to Semrau, which produced inconsistent results across three sessions and ultimately indicated Semrau was generally truthful about his good-faith billing practices, though it could not identify which specific questions he answered truthfully. Laken's claimed accuracy rate came only from laboratory studies and dropped upon further testing, and the district court excluded his testimony; Semrau appealed.
Whether expert testimony about a lie-detection test result is admissible where the test's error rate is known only from laboratory conditions rather than real-world settings, and the test cannot identify which specific answers were truthful or deceptive.