Can a confession be obtained through "implied promises of leniency" in a criminal case?

Appellant also contends his confession was obtained through "implied promises of leniency" in that the police repeatedly told him "he would only be 'helping himself if he gave a full confession...." The law is to the contrary. "[M]ere advice of exhortation by the police that it would be better for the accused to tell the truth when unaccompanied by either a threat or a promise does not render a subsequent confession involuntary. [Citation.]... '[W]hen the benefit pointed out by the police to a suspect is merely that which flows naturally from a truthful and honest course of conduct, ' the subsequent statement will not be considered involuntarily made. [Citation.]" (People v. Jimenez (1978) 21 Cal.3d 595, 611-612, overruled on other grounds in People v. Cahill (1993) 5 Cal.4th 478, 510, fn. 17.) The record demonstrates that appellant was merely being offered the opportunity to clear his conscience by telling the truth about what

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