Contemporary research conducted on the prefrontal cortex has criticized this standpoint because it considers impaired volition as a factor. Many researchers and courts are beginning to consider "irresistible impulse" as legitimate grounds for mental illness. One of the factors neuroscience has added to the insanity defense is the claim that the brain “made someone do it.” In these cases, the argument is based on the notion that an individuals decisions are made for them, before they are able to consciously realize what they are doing.