How has the defence argued the voluntariness rule in a sexual assault case?

In making this argument, the defence stresses that voluntariness is concerned not just with threats and promises but with an examination of all of the circumstances; voluntariness must be considered in the broadest context. If the circumstances under which a statement is made take away the accused’s free will to decide to speak or remain silent, the resulting statement cannot be said to be voluntary. The defence says that the voluntariness rule also encompasses situations where the circumstances created or manipulated by the police are coercive, even though there were no overt threats or promises. In making this argument, the defence stresses the line of cases following Horvath v. The Queen, 1979 CanLII 16 (SCC), [1979] 2 S.C.R. 376.