What is the test for determining whether a defendant's statement was voluntary?

Defendant relies on People v. Flores (1983) 144 Cal.App.3d 459, in which the court held that a defendant's statement was involuntary. The police told the defendant, who was suspected of murder, "'we need you to help yourself out of this mess'"; that statement followed statements about the death penalty, and the clear implication was that "[o]nly by confessing his involvement in the decedent's death could the appellant avoid the possible death penalty." (Id. at p. 471.) Here, unlike in Flores, the record shows no discussion of possible penalties, let alone a discussion of the death penalty.

Considering all the circumstances, we conclude the trial court did not err in determining that defendant's statement was voluntary.

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