In the case of People v. Ladell Deangelo Brown, the Court of Appeal, Third District, California affirmed the conviction of Brown who had admitted that he had shot the victim, Victor Jones. At trial Dr. Richard Ofshe "testified about research showing that modern interrogation techniques lead to false confessions. Ofshe opined that Overall [the investigating officer] induced defendant to admit he shot Victor accidentally or in self-defense by leading defendant to believe he would receive leniency. He noted that Overall never told defendant he remained subject to serious criminal liability under the felony-murder rule. Citing the totality of the circumstances, the court ruled that defendant's admissions were voluntary and denied the motion to suppress."