In what circumstances have the courts considered whether police interrogation produced a confession?

2 In Collazo v. Estelle, 940 F.2d 411 (9th Cir.1991), cert. denied, 112 S.Ct. 870 (1992), the primary issue was whether police interrogation had produced the defendant's subsequent confession. In Derrick v. Peterson, 924 F.2d 813 (9th Cir.1990), cert. denied, 112 S.Ct. 161 (1991), the primary issue was whether the defendant had knowingly and intelligently waived his Miranda rights. Here, by contrast, the issue is whether the officer's statement constituted interrogation in the first place.