The following excerpt is from Collazo v. Estelle, 940 F.2d 411 (9th Cir. 1991):
The factors that are relevant to determining the effect of previous police coercion have been spelled out in United States v. Patterson, 812 F.2d 1188, 1192 (9th Cir.1987). They are whether (1) there was a break in the stream of events sufficient to insulate the statement from the effect of the prior coercion, (2) it can be inferred that the coercive practices had a continuing effect that touched the subsequent statement, (3) the passage of time, a change in the location of the interrogation, or a change in the identity of the interrogators interrupted the effect of the coercion, and (4) the conditions that would have precluded the use of a first statement had been removed.
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