In this opinion the court references the case Vent v. State (67 P.3d 661 Alaska App. 2003) in which the Alaska Court of Appeals upheld the lower court's decision to preclude the testimony of Dr. Richard Leo on the issue of false confessions. The lower court had found that "Dr. Leo's testimony would not appreciably aid the jury in determining whether Vent made a false confession." The trial court judge was also "troubled by the fact that there was no way to quantify or test Dr. Leo's conclusions that certain techniques might lead to a false confession. He also concluded that jurors would be aware that some people do make false confessions and that this proposition could be developed by questioning and argument."