What is the effect of undercover officers' subterfuge in the course of a criminal investigation on a defendant's confession?

Due process is not offended unless the subterfuge or "trickery" the officers used is of the type likely to produce false statements. (See People v. Hogan (1982) 31 Cal.3d 815, 841 ["The question posed by the due process clause in cases of claimed psychological coercion is whether the influences brought to bear upon the accused were 'such as to overbear petitioner's will to resist and bring about confessions not freely selfdetermined'"]; People v. Chutan (1999) 72 Cal.App.4th 1276, 1280 ["Police trickery that occurs in the process of a criminal interrogation does not, by itself, render a confession involuntary and violate the state or federal due process clause"].) Here, there is nothing to show that his statements were unreliable because of the police subterfuge. His description of the shooting remained consistent whether he was speaking in the jail cell with the undercover officers, to the detectives in his recorded statement, or at trial. Likewise, there is no reason to believe that Flint acted any differently, or used language

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