Generally, the courts have found that the use of artifice, stratagem, and deception by law enforcement officers does not, by itself, render an otherwise voluntary confession inadmissible; however, the use of certain extreme forms of deception, e.g., the 'reverse lineup' technique discussed by the Supreme Court in Miranda v. Arizona, could result in a finding of inadmissibility on grounds that they render a confession unreliable, violate the constitutional doctrine of 'fundamental fairness,' or have the effect of overbearing a defendant's right of 'free and rational choice.' Additionally, when deception takes the form of a promise of leniency or assistance in return for a confession, or is used to make a promise more plausible, the chances that the confession will be found involuntary and therefore inadmissible are greatly increased. Also, a misrepresentation of constitutional rights, such as telling a defendant he/she is required to give a statement, can be expected to result in suppression of the confession. If other circumstances known to the investigator suggest that a confession could be successfully challenged on voluntariness grounds, deception should be avoided. It should also be recognized that although the use of deception by itself may not render a confession inadmissible, the use of deception will almost certainly be brought out by the defense, which could impact on the weight given the confession by the court or jury. Finally, should a confession be found involuntary on appeal, the state is precluded from arguing that the error was harmless; therefore, the conviction must be reversed even though the other evidence admitted at trial was sufficient to warrant conviction. Thirty footnotes are provided.