Schneider proposes that by testing a historian against the criteria of the "objective historian" then, even if a historian holds specific political views (and she gives an example of a well-qualified historian's testimony that was disregarded by a United States court because he was a member of a feminist group), providing the historian uses the "objective historian" standards, he or she is a "conscientious historian". It was Irving's failure as an "objective historian" not his right-wing views that caused him to lose his libel case, as a "conscientious historian" would not have "deliberately misrepresented and manipulated historical evidence" to support his political views.