The Rorschach Comprehensive System has been considered by W. M. Grove and R. C. Barden (1999) as inadmissible for expert psychological testimony according to the guidelines from the Daubert (1993), Joiner (1997), and Kumho (1999) decisions. This article refutes W. M. Grove and R. C. Barden's conclusions, arguing that the Rorschach Comprehensive System is (a) testable, (b) valid and reliable, (c) extensively peer reviewed, (d) associated with a reasonable error rate, (e) standardized, (f) accepted by a relevant and substantial scientific community, and (g) appropriate for a wide range of forensic issues. In drawing their negative conclusions, W. M. Grove and R. C. Barden overlooked or minimized a substantial body of empirical data supporting the reliability and validity of the Rorschach Comprehensive System and misinterpreted the language and intent of the Supreme Court decisions.
In reply to Grove et al. (2002), the authors attempt to limit their focus on the question of admissibility of the Rorschach Comprehensive System for expert testimony under the guidelines of the U.S. Supreme Court Daubert/Kumho/Joiner decisions. The article refutes the argument that a "raging controversy" exists as evidence that the Rorschach is not accepted in the field of psychology. The authors again argue that Grove et al. have misconstrued the intent of Daubert/Kumho and misidentify nonclinician academics as the appropriate evaluators of the admissibility of the Rorschach. The authors add to their previous argument ( 2002) that the Rorschach has sufficient reliability, validity, and error rates to be admissible under Daubert and conclude by countering the Grove et al. argument that the Journal of Personality Assessment is not an adequate forum for peer review of the Rorschach.With the addition of two members of a familiar group of Rorschach critics, the arguments by Grove et al. (2002) no longer center on the Daubert/Joiner/ Kumho Supreme Court decisions but shift to what the authors consider to be wrong with the Comprehensive System in general. A few new criticisms are introduced, but much of the rejoinder repeats arguments previously published elsewhere by members of the same team of critics. While the original Daubert/ Joiner/Kumho issues are given short shrift, the authors add a new consideration for expert testimony involving the Rorschach; i.e., their designation of the university professor as arbiter of the admissibility of expert testimony-a consideration absent from the Supreme Court's decisions on expert evidence. Grove et al. (2002) appear to have lost track of the context of their original article and our reply. We are not attempting to mount a comprehensive defense against all criticisms to which the Rorschach has been subjected in the scientific and professional literature. Instead, we limit ourselves to the central issues bearing on the admissibility of expert opinions based on Rorschach assessment. Most of the scattered criticisms Grove et al. now raise have already been definitively answered in the special series in
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