The more common (and some believe more reliable) approach used by all federal courts and most state courts is the 'gatekeeper' model, which is a test formulated from the US Supreme Court cases "Daubert v. Merrell Dow Pharmaceuticals" (509 U.S. 579 "General Electric Co. v. Joiner" (522 U.S. 136 [1997), and "Kumho Tire Co. v. Carmichael" (526 U.S. 137 ). Before the trial, a Daubert hearing will take place before the judge (without the jury). The trial court judge must consider evidence presented to determine whether an expert's "testimony rests on a reliable foundation and is relevant to the task at hand." (Daubert, 509 U.S. at 597).