The following excerpt is from Sessoms v. Grounds, 776 F.3d 615 (9th Cir. 2014):
own trial. Id. (citing Griffin v. California, 380 U.S. 609, 613615, 85 S.Ct. 1229, 14 L.Ed.2d 106 (1965) ). That exception was not at issue in Salinas and is not at issue here. See id. at 217980. Nor did the second exceptionthe presence of governmental coercion [rendering] his forfeiture of the privilege involuntaryapply to Salinas. Id. at 2180. Sessoms did not claim this exception in the state court proceedings. Accordingly, we do not rest our analysis on either exception to the Fifth Amendment privilege.
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