The following excerpt is from USA. v. Orso, 266 F.3d 1030 (9th Cir. 2001):
Orso next argues that Inspector Galetti engaged in coercive conduct by misrepresenting a piece of the evidence against her when he falsely stated that a witness thought Orso had used a gun in commission of the robbery. While reprehensible, this use of deception, however, does not constitute coercive conduct. Frazier v. Cupp, 394 U.S. 731, 737-739 (1969) (holding that confession was voluntary even though the officer falsely told the suspect that his co-conspirator had confessed to the crime).
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