In People v. Albertson (1944) 23 Cal.2d 550, Justice Traynor discusses at length the rule that false statements by a defendant to those investigating the commission of a crime are admissible if they indicate a consciousness of guilt. However, he does not mention any limitation on that rule where a defendant's testimony at trial is consistent with his pretrial statements, but instead suggests a different practice: "Before evidence of false statements by a defendant may be received, the court must determine whether the falsehood is one that may be reasonably construed as implying such an admission; otherwise evidence might be received that is in no way relevant to the issues and therefore seriously prejudicial to the defendant because it indicates to the jury that he is a dishonest person." (23 Cal.2d at p. 582.) In Albertson , at page 581, Justice Traynor observes that false (hearsay) statements by a defendant to those investigating the commission of the charged crime are admissible (as admissions) if they indicate a consciousness of guilt. He adds: "It has never been suggested, however, that every falsehood voiced by the defendant between the time of the crime and the trial can be admitted on this basis, for it is well known that all persons are liable to make errors in the description of past events. Consciousness of guilt is proved, not by evidence of such slips, but by fabrications which, like devious alibis, are apparently motivated by fear of detection, or which, like devious explanations of the possession of stolen goods, suggest that there is no honest explanation for incriminating circumstances and thus are admissions of guilt. Before evidence of false statements by a defendant may be received, the court must determine whether the falsehood is one that may be reasonably construed as implying such an admission; otherwise evidence might be received that is in no way relevant to the issues and therefore seriously prejudicial to the defendant because it indicates to the jury that he is a dishonest person." (At p. 582.)