In what circumstances have the courts interpreted "implied coercion" in a search warrant application?

Defendant also cites Amos v. United States (1921) 255 U.S. 313. There, however, officers went to the defendant's home and told his wife "that they were revenue officers and had come to search the premises 'for violations of the revenue law' . . . ." (Id. at p. 315.) She then let them in. (Ibid.) The court held that the wife did not voluntarily consent to the search because "demanding admission to . . . search . . . under [g]overnment authority" constituted "implied coercion." (Id. at p. 317.) Here, Deputy Mamon never made any such demand.

Second, defendant points out that not just one but two officers were present. However, People v. Munoz (1972) 24 Cal.App.3d 900 held that "[t]he fact there were four officers does not in itself carry an implied assertion of authority . . . ." (Id. at p. 905.) A fortiori, the presence here of only two officers did not overbear defendant's will.