Undercover police operatives posing as criminals are not 'persons in authority' for the purposes of the confessions rule where the accused does not know or believe them to be police, and inducements offered in that context are not cloaked with authority. Deception as to identity does not of itself render a confession basally involuntary where the accused was given a genuine choice to speak or remain silent. The overall discretion to exclude confessional statements obtained through elaborate undercover operations will not be exercised where the operation occurred at the investigative stage, did not circumvent an express refusal to speak to police, did not exploit custody or a pre-existing relationship, involved a serious crime, and encouraged truthfulness.
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