In Memphis, Tenn., Arthur Baldwin was convicted for possession with intent to use and distribute cocaine based on evidence obtained in his home by an undercover officer who worked as Baldwin's personal employee and lived in his home for 6 months. The undercover operation was initiated without suspicion of illegal behavior by Baldwin. The U.S. Supreme Court denied Baldwin's petition for a writ of certiorari. The Supreme Court's refusal to acknowledge pressing constitutional issues in this case is inconsistent with the Court's interpretation of privacy rights in other similar cases. Deceptive police undercover practices have been exempted by the courts from judicial review for probable cause, usually required before police can search and seize evidence in a private home. This exemption is based in the view that the voluntary admission of an undercover police officer into one's private life constitutes a waiver of any claim to a privacy violation. A new standard should be established to prevent the undercover investigation of a person by any one agency for more than 24 hours without a court-approved warrant. Twenty notes are listed.