While police have made false statements to suspects to induce confessions, some courts have refused to hold such deceptive police conduct unconstitutional because they have been unable to agree on what constitutes unconstitutional coercion. The article points out that the trickery, when used by police, should be defined as eliciting a confession from a suspect by the deliberate distortion of a material fact, by failure to disclose a material fact to the suspect, or by playing on the suspect's emotions or scruples. Policy concerns underlying the legal analysis of police trickery are discussed, along with the Supreme Court's treatment of police trickery in obtaining confessions and its failure to proscribe such behavior. Because the Court has held that coerced confessions are involuntary and therefore unconstitutional, it should, to be consistent, also rule that confessions resulting from police trickery are involuntary and unconstitutional. A standard for making confessions resulting from police trickery inadmissible at trial is proposed. 148 footnotes.