Polygraph evidence has been the pariah of the courtroom since the adoption of the "general acceptance" test for the admission of scientific evidence in Frye v. United States.' While the Frye court's decision to exclude lie detector evidence was correctly based upon the state of polygraph technology at that time, many courts have subsequently failed to recognize the many advances in polygraphy and have excluded test results without further consideration.2 Indeed, polygraph evidence seems to be considered by courts, in practice if not in actual theory, to be sui generis. Recent trends toward the recognition of polygraph evidence as having a degree of reliability have resulted in many courts taking a new look at the admissibility of polygraph evidence While many other courts have modified their outdated approaches to the admission of polygraph evidence, Missouri courts are still applying the Frye test4 and, it seems, are using any other available excuse to prevent the admission of polygraph evidence.

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