Criminal
Sep. 1, 2026
Perkins operations and constitutional limits: Lessons from People v. Zapata
The Court of Appeal's decision in People v. Zapata clarifies the constitutional limits of undercover jailhouse operations while preserving a critical investigative tool for law enforcement.
Jason Zapata invoked his right to counsel. Law enforcement placed him back in a holding cell with two undercover agents and used deliberate "stimulation" tactics--a fake lineup and the announcement of a murder charge in the agents' presence. Zapata made incriminating statements and was convicted of second-degree murder. In February 2026, the Fourth District Court of Appeal reversed that conviction in People v. Zapata (2026) 118 Cal.App.5th 529 (D084024), finding the ...
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