In this case, the court refused to allow the submission of this testimony. The majority holding was that such testimony invades the province of the jury as trier of fact. The dissenting opinion held that precedents may be outdated and that the value of expert testimony on eyewitness unreliability should be reexamined. Prior to 1972, expert testimony on eyewitness accuracy was virtually unheard of: eyewitness testimony was uniformly accepted and its accuracy generally assumed. Prior to 1983, no appellate court had reversed a lower court decision to refuse to admit such expert testimony on this issue. In the early 1970's, some publicized cases of mistaken eyewitness identification led to research, which, in turn, paved the way for a set of cases in which courts were willing to accept expert testimony. This gradual acceptance prompted a backlash, and psychologists began publicly to question the methodology and interpretation of the studies underlying expert testimony. This led to new skirmishes that have produced a 'battle of the experts.' Several courts have taken the initiative in promoting the use of expert testimony as a means of counteracting the potential for eyewitness error, and Kansas and California courts now require extensive juror instructions when eyewitness testimony is critical. It is likely that current trends toward acceptance of research results on eyewitness reliability will continue. 259 references.