Are police officers necessarily more trustworthy than alleged criminals? The police have a special inclination toward confabulation ... because, disturbingly, they have an incentive to lie. In this era of mass incarceration, the police shouldn't be trusted any more than any other witness, perhaps less so. That may sound harsh, but numerous law enforcement officials have put the matter more bluntly. Peter Keane, a former San Francisco Police commissioner, wrote [that] Police officer perjury in court to justify illegal dope searches is commonplace. One of the dirty little not-so-secret secrets of the criminal justice system is undercover narcotics officers intentionally lying under oath. It is a perversion of the American justice system that strikes directly at the rule of law. Yet it is the routine way of doing business in courtrooms everywhere in America." The New York City Police Department is not exempt from this critique. New York City officers have been found to engage in patterns of deceit in cases involving charges as minor as trespass. Jeannette Rucker, the chief of arraignments for the Bronx district attorney, explained in a letter that it had become apparent that the police were arresting people even when there was convincing evidence that they were innocent. To justify the arrests, Ms. Rucker claimed, police officers provided false written statements, and in depositions, the arresting officers gave false testimony.