What is the test for making a statement to his mother that was not an involuntary one?

California, United States of America


The following excerpt is from People v. Wong, A137584 (Cal. App. 2015):

Upon an independent review of the record, we find no reason to disagree with the trial court's decision. As defendant recognizes, his conversation with his mother is not considered the equivalent of a police interrogation. (People v. Tate (2010) 49 Cal.4th 635, 685-686.) Even were that not the case, we find no circumstances that would have rendered his statements to his mother involuntary. Although defendant was injured

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