As a rule, police officers must advise suspects held in custody of their rights before interrogating them. In Illinois v. Perkins, the Supreme Court created an undercover agent exception to this rule. The Perkins Court concluded that the rule does not apply because undercover interrogations do not compel criminal defendants to incriminate themselves. This Note examines the impact of the Perkins exception and concludes that the rule should apply even when undercover agents conduct the inherently compelling custodial interrogation
