Strategic Deception Revisited: The Use of Fabricated Documents during Interrogation—Permissible Ploy or Prohibited Practice?

Law enforcement officials understand that service in their profession requires character and values and not simply technical proficiency. One of these values is honesty, which requires an officer to avoid such behaviors as lying for personal gain or during judicial proceedings. However, the U.S. Supreme Court has recognized that the duties of law enforcement may require limited officially sanctioned deception in the course of a criminal investigation.