Even before DNA testing revealed wrongful convictions based on eyewitness identifications, courts recognized and discussed the limits of eyewitness testimony. The late U.S. Supreme Court Justice William J. Brennan, Jr. observed in 1980 that "At least since "United States v. Wade", 388 U.S. 218 (1967), the Court has recognized the inherently suspect qualities of eyewitness identification evidence, and described the evidence as "notoriously unreliable", while noting that juries were highly receptive to it. Similarly, in the United Kingdom, the Criminal Law Review Committee, writing in 1971, stated that cases of mistaken identification "constitute by far the greatest cause of actual or possible wrong convictions".