Far from embracing an “epistemic” confusion (category mistake?), the Missouri Supreme Court simply recognized in Jackson what many courts have long known: a jury’s disbelief of evidence can itself be evidence. “Where an unresolved factual dispute exists” – which is the norm in criminal trials – “demeanor evidence is a significant factor in adjudging credibility. And questions of credibility, of course, are basic to resolution of conflicts in testimony. ”13 As Judge Learned Hand observed, “the carriage, behavior, bearing, manner and appearance of a witness – in short, his ‘demeanor’ – is a part of the evidence. ”14 Demeanor “evidence may satisfy the tribunal, not only that the witness’ testimony is not true, but that the truth is the opposite of his story; for the denial of one, who has a motive to deny, may be uttered with such hesitation, discomfort, arrogance or defiance, as to give assurance that he is fabricating, and that, if he is, there is no alternative but to assume the truth of what he denies.…