In their February 23, 2012 article, "Why Do Innocent People Confess?" in the discussion of false confessions the author points out that John E. Reid and Associates teaches interview and interrogation techniques that are consistent with judicial decisions and guidelines. For example, when reading the Miranda rights, the United States Supreme Court has stated that there is no requirement "that the content of the Miranda warnings be a virtual incantation of the precise language contained in Miranda." The US Supreme Court has also stated with respect to the misrepresentation of evidence that it is "while relevant, insufficient in our view to make this otherwise voluntary confession inadmissible. These cases must be decided by viewing the 'totality of circumstances'." Clearly an interrogator can not make any promises of leniency to a suspect in return for a confession, but as one court stated, " There is nothing problematic or objectionable about police, when questioning suspects, in downplaying or minimizing the moral culpability of their alleged criminal activity. I find there was nothing improper in these and other similar transcript examples where [ the detective] minimized [the accused's] moral responsibility."