"Letting police get away with manufacturing confessions or planting evidence not only risks convicting the innocent but helps the guilty avoid detection and strike again." -Ninth Circuit Chief Judge Alex Kozinski, concurring with his own majority opinion setting aside a woman's murder conviction and death sentence and ordering her release after 23 years in prison. (Milke v. Ryan, 711 F.3d 998, 1024 (9th Cir. 2013).) In adding his own comments, Kozinski said he would have ruled that the conviction "relied on an illegally-obtained confession that probably never occurred."