The legal standards addressing the treatment of eyewitness testimony as evidence in criminal trials vary widely across the United States on issues ranging from the admissibility of eyewitness testimony as evidence, the admissibility and scope of expert testimony on the factors affecting its reliability, and the propriety of jury instructions on the same factors. In New Jersey, generally considered a leading court with respect to criminal law, a report was prepared by a special master during a remand proceeding in the case of "New Jersey v. Henderson" which comprehensively researched published literature and heard expert testimony with respect to eyewitness identification. Based on the master's report the New Jersey court issued a decision on August 22, 2011 which requires closer examination of the reliability of eyewitness testimony by trial courts in New Jersey. "Perry v. New Hampshire", a case which raised similar issues, was decided January 11, 2012 by the U.S. Supreme Court. which in an 8–1 decision decided that judicial examination of eye-witness testimony was required only in the case of police misconduct.Held: The Due Process Clause does not require a preliminary judicial inquiry into the reliability of an eyewitness identification when the identification was not procured under unnecessarily suggestive circumstances arranged by law enforcement.The preeminent role of the jury in evaluating questionable evidence was cited by the court.