In the New York Times, Adam Liptak has a piece on the trend of Supreme Court opinions accepting and restating facts appearing in amicus briefing, some of which facts are later revealed to be erroneous or based on questionable studies: "Seeking Facts, Justices Settle for What Briefs Tell Them." This is a phenomenon that was heavily criticized by Justice Scalia in his dissent in Sykes v. United States, No. 09-11311 (2011):