Certain criticisms have been waged against the "Manson" standard, however. According to legal scholars, "the rule of decision set out in "Manson" has failed to meet the Court's objective of furthering fairness and reliability." For example, the Court requires that the confidence of the witness be considered as an indicator of the reliability of the identification evidence. As noted above, however, extensive studies in the social sciences have shown that confidence is unreliable as a predictor of accuracy. Social scientists and legal scholars have also expressed concern that "the ["Manson"] list as a whole is substantially incomplete," thereby opening the courthouse doors to the admission of unreliable evidence.