Psychological coercion motivated the Miranda rule, but in 1990, the United States Supreme Court appeared to condone police deception in eliciting incriminating remarks from criminal suspects. The discussion examines post-Perkins lower-court cases to clarify the doctrine and to provide guidance on the meaning of a police-dominated environment, explores why jailhouse police informants can use more trickery and deception before formal charges are filed than after indictment, and applies a four-part "ends-justifies-the-means" test to the Court's rationale as enunciated in Perkins. A new crime-control bright-line test, that is, a strict and perspicuous rule that makes procedures clear and precise, is taking the place of the original due process-oriented Miranda rule. Most likely, the expanded power of police investigative practices as condoned in Perkins and Wilson will encourage police deception and trickery. 7 notes and 25 references