Is a confession involuntary if it is coerced by the police?

Coercive police activity is a necessary predicate to a finding that a confession is involuntary. (Colorado v. Connelly (1986) 479 U.S. 157.) A statement is involuntary when -- among other circumstances -- it was extracted by threats or obtained by a direct or implied promise. (Dykes, supra, 46 Cal.4th at p. 752.) "A confession is 'obtained' by a promise within the proscription of both the federal and state due process guarant[ees] if and only if inducement and statement are linked, as it were, by 'proximate' causation." (People v. Benson, supra, 52 Cal.3d at p. 778.) In considering

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