This decision appeared to clear the way for law enforcement to take advantage of a very effective investigative technique. The permissible use of cellmate informants was again questioned, however, when Perkins subsequently argued in State court that use of the technique violated his previously invoked Miranda right to counsel. Because the U.S. Supreme Court refused to hear the case a second time, the extent to which cellmate informants can be used lawfully against suspects who have earlier invoked a right to counsel remains open to debate in both lower Federal courts and State courts. Confined suspects often have an overwhelming desire to talk about their criminal activities with those they considered their peers. Police officers can take advantage of this phenomenon by placing an informant in prison but must be aware of constitutional boundaries set by the fifth and sixth amendments. The U.S. Supreme Court decision is analyzed in terms of self-incrimination, due process, and right to counsel. 44 endnotes