This op-ed criticizes a recent Ohio Supreme Court case, In re M.H., in which the Court held that the confession of a juvenile to a child protective services officer was voluntary. According to the Court's plurality opinion, a confession can be rendered involuntary only when a police officer conducts the interrogation. Thus, no matter what the child protective services investigator does during an interrogation, a resulting confession is always voluntary simply because the interrogator is not a police officer. Witmer-Rich criticizes this rule as inconsistent with fundamental principles of liberty and due process.