California, United States of America
The following excerpt is from People v. Serna, H041769 (Cal. App. 2018):
Second, Serna's claim that the length of time between his arrest and initial interrogation contributed to the psychological coercion is unpersuasive. Certainly, relinquishment of Miranda rights must be made by a defendant's free choice, not by intimidation, coercion, or deception. (People v. Clark, supra, 5 Cal.4th at p. 986.) Serna,
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however, does not point to anything in the record that suggests the delay in the interrogation was some type of psychological coercion employed by the police. (See People v. Williams (1997) 16 Cal.4th 635, 659 ["A confession or admission is involuntary, and thus subject to exclusion at trial, only if it is the product of coercive police activity."].)
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