2003 in the case of State v. Patton 826 A.2d 783, N.J.Super.A.D.,2003 the court very carefully examines the use of trickery and deceit in the interrogation of suspects, and draws a very clear distinction between verbally misrepresenting evidence and creating a fictitious piece of evidence. In their opinion the court extensively reviews the history of the trickery and deceit issue and what numerous courts have had to say on the issue.