In Massiah v. United States, 377 U.S. 201, 84 S. Ct. 1199, 12 L. Ed. 2d 246 (1964), the United States Supreme Court held that incriminating statements elicited by a government agent outside the presence of counsel cannot be admitted against a defendant at trial. In United States v. Henry, 447 U.S. 264, 100 S. Ct. 2183, 65 L. Ed. 2d 115 (1980), the United States Supreme Court interpreted Massiah to apply when a state places an undercover jailhouse informant in the same cell as a defendant and instructs the informant to be alert to any incriminating statements made by the defendant.