In the murder trial of Adrian Thomas in Troy, New York, the prosecution's expert witness at the Frye hearing, Professor Paul Cassell, conclusively opined that

according to FBI figures, there are 900,000 arrests per year which, over a 23-year period add up to 20 million. [the expert witness] divided this figure by 60, which was the number of confessions that Dr. Ofshe had identified as false in a 1996 article. From this, [the expert witness] concluded that the frequency of false confessions is one hundredth of one percent.