Phrenology is unscientific -- it is junk science -- and it does not meet the requirements under Federal Rule of Evidence for the admissibility of expert evidence.

United States v. Armendariz-Mata, 949 F.2d 151, 154-155 (5th Cir. 1991) (upholding trial court's admission of government's evidence of accused's drug trafficking activities and his association with a drug trafficker because accused, by raising the entrapment defense, placed his predisposition at issue and...A subjective entrapment defense makes an accused's criminal liability contingent on a finding of the accused's predisposition or the accused's lack of predisposition to commit the crime charged and since criminal predisposition is a character trait, the defense of subjective entrapment makes accused's character an element of either a defense or a criminal charge, evidence of accused's criminal predisposition -- including evidence in the form of reputation, opinion, and evidence of specific instances of accused's conduct -- is not barred by the rule against the use of a person's character to show the person's conduct.

Cf. Stovall v. Denno, 388 U.S. 293, pin? (1967) ("[A] recognized ground of attack upon a conviction independent of any right to counsel claim" is that a pretrial eyewitness identification was 'so unnecessarily suggestive and conducive to irreparable mistaken...The federal constitutional guarantee of due process may limit the government's right to introduce unreliable hearsay evidence against a defendant in a criminal trial.

Cf. United States v. Dixon, 413 F.3d 520, 525 (5th Cir. 2005) (upholding trial court's exclusion of the inculpatory statements of defendant's boyfriend to an ATF agent because of "a major inconsistency between....If a statement is offered against a criminal defendant, the statement qualifies as a statement against interest for purposes of the federal hearsay exception for statements against interest only if there is corroborating evidence of the trustworthiness of the statement.