assessments of polygraphy by scientific and government bodies generally suggest that polygraphs are inaccurate, may be defeated by countermeasures, and are an imperfect or invalid means of assessing truthfulness. Despite claims that polygraph tests are between 80% to 90% accurate by advocates, the National Research Council has found no evidence of effectiveness. In particular, studies have indicated that the relevant–irrelevant questioning technique is not ideal, as many innocent subjects exert a heightened physiological reaction to the crime-relevant questions. The American Psychological Association states "Most psychologists agree that there is little evidence that polygraph tests can accurately detect lies." In 2002, a review by the National Research Council found that, in populations "untrained in countermeasures, specific-incident polygraph tests can discriminate lying from truth telling at rates well above chance, though well below perfection". The review also warns against generalization from these findings to justify the use of polygraphs—"polygraph accuracy for screening purposes is almost certainly lower than what can be achieved by specific-incident polygraph tests in the field"—and notes some examinees may be able to take countermeasures to produce deceptive results. In the 1998 US Supreme Court case United States v. Scheffer, the majority stated that "There is simply no consensus that polygraph evidence is reliable [...] Unlike other expert witnesses who testify about factual matters outside the jurors' knowledge, such as the analysis of fingerprints, ballistics, or DNA found at a crime scene, a polygraph expert can supply the jury only with another opinion." The Supreme Court summarized their findings by stating that the use of polygraph was "little better than could be obtained by the toss of a coin." In 2005, the 11th Circuit Court of Appeals stated that "polygraphy did not enjoy general acceptance from the scientific community". In 2001, William Iacono, Professor of Psychology and Neuroscience at the University of Minnesota, concluded: Although the CQT [Control Question Test] may be useful as an investigative aid and tool to induce confessions, it does not pass muster as a scientifically credible test. CQT theory is based on naive, implausible assumptions indicating (a) that it is biased against innocent individuals and (b) that it can be beaten simply by artificially augmenting responses to control questions. Although it is not possible to adequately assess the error rate of the CQT, both of these conclusions are supported by published research findings in the best social science journals (Honts et al., 1994; Horvath,