California, United States of America
The following excerpt is from People v. Rodriguez, B288312 (Cal. App. 2019):
15. A claim a suspect's statements have "actually been coerced" (Oregon v. Elstad (1985) 470 U.S. 298, 310-311 (Oregon)), or are "involuntary" (Dickerson v. United States (2000) 530 U.S. 428, 444 (Dickerson), is separate and distinct from a claim that the admission of statements violated the Miranda rule. (Oregon, at p. 310; Dickerson, at p. 444; Ariz. v. Fulminante (1991) 499 U.S. 279, 285-286, 287, fn. 3 [examining totality of circumstances to determine whether confession was actually coerced and noting court has used the terms " 'coerced confession' " and " 'involuntary confession' " interchangeably].)
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