In the case of People v. Fuentes, the Court of Appeal, Second District, California found the defendant's confession to be inadmissible because improper promises and threats were made during the interview, both express and implied, which rendered the confession involuntary as the product of coercive police activity. From the Apeal Court's decision:

"In making this argument, defendant focuses on exhortations that even good people can do bad things while intoxicated and that defendant's not being in his ìright state of mindî when the incident happened would ìhelpî him. In addition, defendant was told that not confronting the situation would be ìworseî for him, if defendant lied the case would go ìvery, very badî for him, and if defendant kept quiet he could be charged ìfor something more serious, very ugly.î Conversely, if a person tells the truth ìit goes much better for themî and ìthe charges are lowered - a little.î Finally, at least one and one-half hours after the interview started, defendant was given the alternative of spending either ìthe rest of [his] lifeî or ìfive or six yearsî in jail. He then confessed. In addressing the issue of voluntariness, the trial court concluded that under the totality of the circumstances the ìlatitudeî taken by the police in questioning defendant was permissible. Based on our independent review of this legal issue, we reach the opposite conclusion (and therefore do not need to analyze the separate issue of defendant's Miranda waiver)."