The following excerpt is from People v. Dunbar, 2014 N.Y. Slip Op. 07293, 23 N.E.3d 946, 24 N.Y.3d 304, 998 N.Y.S.2d 679 (N.Y. 2014):
Dickerson v. United States, 530 U.S. 428, 443, 120 S.Ct. 2326, 147 L.Ed.2d 405 [2000] ). Prior to the Miranda decision, courts looked at every confession individually for voluntariness, using a totality-of-the-circumstances test grounded in notions of due process (id. at 432433, 120 S.Ct. 2326 ). This due process test took into consideration the totality of all the surrounding circumstancesboth the characteristics of the accused and the details of the interrogation (id. at 434, 120 S.Ct. 2326 [internal quotation marks omitted] ).
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