What is the test for whether a confession was involuntary?

California, United States of America


The following excerpt is from People v. Westmoreland, 153 Cal.Rptr.3d 267 (Cal. App. 2013):

7 Appellant also argues his confession was involuntary because "the interrogators repeatedly lied to appellant that his fingerprints had been found inside the apartment where the homicide took place, that his sister had inculpated him, and that his girlfriend might be released." We reject that contention because those deceptions were "not of a type reasonably likely to procure an untrue statement." (People v. Farnam (2002) 28 Cal.4th 107, 182, 121 Cal.Rptr.2d 106, 47 P.3d 988 (Farnam ).)

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