In the case of Crawford v State, the Georgia Court of Appeals held that the trial court did not abuse its discretion in refusing to allow expert testimony on the false confession theory, "which is unreliable and has not reached a verifiable stage of scientific certainty."† In the report of this decision†it was noted that in the case of Riley v State, 278 Ga. 677, 681-683 (4) (604 SE2d 488) 2004 the Georgia Supreme Court has upheld a trial court's refusal to admit expert testimony on the false confession theory because the theory is not reliable.