In State v. Cayward, 552 So. 2d 971 (Fla. Dist. Ct. App. 1989), review dismissed, 562 So. 2d 347 (Fla. 1990), a teenager was suspected of sexually assaulting and smothering his young niece. a two-hour interrogation, the police showed the suspect two scientific reports that had been fabricated as a ploy to induce a confession. Id. at 972. One report was prepared on stationery of the Florida Department of Criminal Law Enforcement; the other was prepared on stationery of Life Codes, Inc., a phony scientific testing organization. The police represented to the suspect that both scientific reports were genuine, and indicated that the test results revealed that Cayward's semen was found on the victim's underwear. Id. At the end of the interrogation, Cayward asked, "What happens now?" The investigator told him, "We are going to the grand jury," and indicated that the State would seek the death penalty. Id. Cayward then confessed. Concluding that the fabrication of the documents and exhibition of them to the suspect violated the defendant's due process rights, the appellate court determined that the defendant's statement was involuntary. Thus, it upheld the trial court's suppression of the confession. Cayward, 552 So. 2d at 972. The Florida court acknowledged that deceptive police conduct does not render a confession involuntary per se. Although the Cayward court recognized the viability of the "totality of the circumstances" test in regard to the determination of voluntariness, it found that there was "a qualitative difference" between the use of verbal "artifices" and the fabrication of bogus documents. Id. at 973. Thus, the court adopted a "bright line" rule, stating that the manufacture and use of false documents by the police to induce a confession "has no place in our criminal justice system." Id. at 974. The Cayward court recognized that, because most people expect police interrogations to take place in a confrontational or adversarial atmosphere, a suspect would probably expect the police to engage in some form of oral deception. In contrast, the court indicated that neither the expectations of the suspect nor the public "encompass the notion that the police will knowingly fabricate tangible documentation...." Id. In the court's view, such police conduct was reminiscent of "the horrors of less advanced centuries in our civilization when magistrates ... schemed with sovereigns to frame political rivals." Id. Indeed, the court regarded such conduct as analogous to "one of the parade of horrors" that our "modern judicial system was designed to correct." Cayward, 552 So. 2d at 974. Therefore, it concluded that "the manufacturing of false documents by police officials offends our traditional notions of due process of law...." Id. In reaching its decision, the Florida court reasoned that, unlike oral misrepresentations, manufactured documents have "the facial appearance of authenticity." Id. Moreover, the court expressed concern that such documents might find their way into official files and even the courtroom. In its view, the erroneous admission of false documents would diminish the public's confidence in both the police and the legal system. Id. at 975.