In Massiah v. U.S. the Supreme Court held that the right to counsel was violated when evidence of incriminating statements deliberately elicited from the defendent in the absence of counsel was used against him. Other principal cases on this right are Brewer v. Williams, 430 U.S. 387 (1977), United States v. Henry, 447 U.S. 264 (1980), and Maine v. Moulton, 106 S. Ct. 477 (1985). The original meaning of the guarantee of assistance of counsel at trial has been expanded over the past half-century by Supreme Court decisions reflecting the core purpose of the Sixth Amendment. The Massiah doctrine is merely a cover for a judicially-imposed policy against the use of post-indictment confessions and admissions. Also, the costs of Massiah's exclusionary rule include the impairment of the truth-finding process that results from suppression of reliable and probative evidence of guilt, the consequent release or lenient treatment of obviously guilty defendents, and the generation of public disrespect for the criminal justice systrem. Litigative, legislative, investigative, administrative, and educational strategies are recommended to achieve reform in this area of law.