lie detector test in California

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2025(People v. Roof, supra, at p. 225 [contributing to the delinquency of a minor with the proceeds of 18 the charged crime]; People v. Bentley, supra, at p. 689 [reference to defendant being a suspect in a separate child molestation case and defendant denying same upon questioning].) In People v. Schiers (1971) 19 Cal.App.3d 102, 108 , an officer testified that the defendant failed a lie detector test and that the defendant said the machine must not have been working when told that he failed the test.

2025And in People v. Schiers (1971) 19 Cal.App.3d 102 , 108–109, the court found improper testimony that a lie detector test showed the defendant was lying to be incurably prejudicial.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015(See, e.g., Rufo v. Simpson (2001) 86 Cal.App.4th 573, 600-604 [counsel’s reference in opening statement to defendant’s willingness to take a lie detector test did not permit plaintiff to inquire into the subject, especially when plaintiff had not objected to the statement]; accord, Winfred D. v. Michelin North America, Inc. (2008) 165 Cal.App.4th 1011, 1027-1028 .) We will therefore assume for purposes of argument that counsel’s remarks did not open the door to the admission of evidence on the subject.

2015(See, e.g., Rufo v. Simpson (2001) 86 Cal.App.4th 573, 600-604 [counsel’s reference in opening statement to defendant’s willingness to take a lie detector test did not permit plaintiff to inquire into the subject, especially when plaintiff had not objected to the statement]; accord, Winfred D. v. Michelin North America, Inc. (2008) 165 Cal.App.4th 1011, 1027-1028 .) We will therefore assume for purposes of argument that counsel’s remarks did not open the door to the admission of evidence on the subject.

2015(See, e.g., Rufo v. Simpson (2001) 86 Cal.App.4th 573, 600-604 [counsel’s reference in opening statement to defendant’s willingness to take a lie detector test did not permit plaintiff to inquire into the subject, especially when plaintiff had not objected to the statement]; accord, Winfred D. v. Michelin North America, Inc. (2008) 165 Cal.App.4th 1011, 1027-1028 .) We will therefore assume for purposes of argument that counsel’s remarks did not open the door to the admission of evidence on the subject.

2015(See, e.g., Rufo v. Simpson (2001) 86 Cal.App.4th 573, 600-604 [counsel’s reference in opening statement to defendant’s willingness to take a lie detector test did not permit plaintiff to inquire into the subject, especially when plaintiff had not objected to the statement]; accord, Winfred D. v. Michelin North America, Inc. (2008) 165 Cal.App.4th 1011, 1027-1028 .) We will therefore assume for purposes of argument that counsel’s remarks did not open the door to the admission of evidence on the subject.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

1969(See People v. Houser (1948) 85 Cal.App.2d 686, 694 [ 193 P.2d 937 ]; 29 Am.Jur.2d, § 831, p. 923.) In the case at bench defendant’s counsel stipulated that defendant would submit to a lie detector test, and also that the results could be received into evidence for the purpose of sentencing.

1969(See People v. Houser (1948) 85 Cal.App.2d 686, 694 [ 193 P.2d 937 ]; 29 Am.Jur.2d, § 831, p. 923.) In the case at bench defendant’s counsel stipulated that defendant would submit to a lie detector test, and also that the results could be received into evidence for the purpose of sentencing.

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2009(E.g., People v. Serrano (2005) 14 A.D.3d 874 [ 788 N.Y.S.2d 272 ] [confession voluntary despite police (apparent) deception in informing the defendant that he failed a polygraph examination]; People v. Sobchik (1996) 228 A.D.2d 800 [ 644 N.Y.S.2d 370 ] [confession voluntary where defendant was hooked up to a polygraph, but it was not turned on]; Contee v. U.S. (D.C. 1995) 667 A.2d 103, 104 [affirmed conviction based on confession obtained after the police (perhaps) untruthfully told the 17-year-old defendant that he failed a computer voice stress analyzer, when in fact the test did not so ind

2009(E.g., People v. Serrano (N.Y.App.Div. 2005) 14 A.D.3d 874 [ 788 N.Y.S.2d 272 ] [confession voluntary despite police (apparent) deception in informing the defendant that he failed a polygraph examination]; People v. Sobchik (N.Y.App.Div. 1996) 228 A.D.2d 800 [ 644 N.Y.S.2d 370 ] [confession voluntary where defendant was hooked up to a polygraph, but it was not turned on]; Contee v. U.S. (D.C. 1995) 667 A.2d 103, 104 [affirmed conviction based on confession obtained after the police (perhaps) untruthfully told the 17-year-old defendant that he failed a computer voice stress analyzer, when in fa

2009People v. Farnam, supra, 28 Cal.4th 107 , held the defendant's confession to robbery and assault of hotel occupants was voluntary, despite the police having falsely informed the defendant that his fingerprints were found on the victim's wallet. ( Id. at pp. 130, 182.) *1155 (4) In California, it has been held that if a defendant takes a lie detector test willingly, "`neither the fact it was given nor the fact that the defendant was told by the test giver it revealed in his opinion that defendant was not telling the truth, inherently demonstrates coercion. [Citation.]'" ( People v. Brown (1981)

2009People v. Farnam, supra, 28 Cal.4th 107 , held the defendant's confession to robbery and assault of hotel occupants was voluntary, despite the police having falsely informed the defendant that his fingerprints were found on the victim's wallet. ( Id. at pp. 130, 182.) *1155 (4) In California, it has been held that if a defendant takes a lie detector test willingly, "`neither the fact it was given nor the fact that the defendant was told by the test giver it revealed in his opinion that defendant was not telling the truth, inherently demonstrates coercion. [Citation.]'" ( People v. Brown (1981)

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2018It is a catalogue of the minimum rights [citation] the Legislature deems necessary to secure stable employer-employee relations [citation].' [Citations.]" ( Mays , supra , 43 Cal.4th at p. 320 , 74 Cal.Rptr.3d 891 , 180 P.3d 935 .) "These rights include limits on and guidelines for investigations and interrogations of public safety officers in connection with disciplinary proceedings (§ 3303), the right to an administrative appeal and a one-year statute of limitations for investigations (§ 3304), the right to notification of adverse comments placed in his or her personnel file and the right to

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2015L.Rev. at p. 904.) In the United States, although deceptive interrogation techniques do not necessarily invalidate incriminating statements (Frazier v. Cupp (1969) 394 U.S. 731, 739 [ 22 L.Ed.2d 684 , 89 S.Ct. 1420 ]; People v. Smith (2007) 40 Cal.4th 483, 505 [ 54 Cal.Rptr.3d 245 , 150 P.3d 1224 ]), they are relevant in considering the totality of the circumstances (Frazier, at p. 739) as “a factor which weighs against a finding of voluntariness [citation].” (People v. Hogan (1982) 31 Cal.3d 815, 840-841 [ 183 Cal.Rptr. 817 , 647 P.2d 93 ], disapproved on other grounds in People v. Cooper (19

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.

2004(See People v. Carter (1957) 48 Cal.2d 737, 752 , 312 P.2d 665 ["Lie detector tests do not as yet have enough reliability to justify the admission of expert *436 testimony based on their results"]; People v. Adams (1975) 53 Cal.App.3d 109, 111-119 , 125 Cal.Rptr. 518 [concluding results of polygraph test inadmissible at trial under doctrine of stare decisis and also because insufficiently reliable]; People v. York (1959) 174 Cal.App.2d 305, 311-312 , 344 P.2d 811 [refusing to reexamine holdings of prior cases finding polygraph examination results inadmissible]; People v. Porter (1955) 136 Cal.