Today, many jurisdictions have abandoned the principle as a formal rule of evidence and instead apply the rule as a "permissible inference that the jury may or may not draw." However, some courts continue to apply the doctrine to discredit witnesses that have previously offered false testimony. In 2013, for example, the United States Court of Appeals for the Ninth Circuit held that in immigration cases, a court may "use an adverse credibility finding on one claim to support an adverse finding on another claim." Likewise, at the O.J. Simpson murder trial, Judge Lance Ito applied the doctrine to instruct the jury that "[a] witness who is willfully false in one material part of his or her testimony is to be distrusted in others."