In a recent case, U.S. v Kasey, the US District Court D. Arizona examined the issue of what statements constitute a promise of leniency that would render a confession inadmissible. They found that such statements as:

"You can help yourself out by telling the truth."

"[T]his is probably going to be a 50-year-to-life-type count. You know you need to mitigate, try to help yourself out...."

"And they'll give the benefit for standing up. Because that's the way the Federal system works for cooperation with the Government. That's the way it works. You get the benefits for doing that. It shows a truthfulness. Whether the truth hurts, you get a benefit for the truth, and the truth can hurt. It's not fun talking about this kind of stuff."

"You just need to make a decision if you want to do something like that to explain to the world why this went down. But it's up to you. I mean, this is to help you. It's not going to help me, I don't need the help."

"They're young like you are. They are trying to do whatever they can to rectify a bad situation and make it in their best interest, and I would do the same thing".

"There's just a huge amount of evidence and when we work with the Apache Detectives and us, that's the kind of cases we put together. And they're very thorough, very solid. So you're young, you need to do something that's going to help you out."

The court stated, "A promise only vitiates consent if it is "sufficiently compelling to overbear the suspect's will in light of all attendant circumstances." Id. at 1366. Reciting possible penalties or sentences does not render a statement involuntary. United States v. Haswood, 350 F.3d 1024, 1029 (9th Cir.2003).

Here, the agents told Defendant that she could help herself by telling her version of the events. There is nothing in the interview transcript to indicate that the agents said or did anything to overbear Defendant's will. Merely stating that Defendant should "help herself by telling her story" is not sufficiently compelling to overbearing her will by offers of leniency. Furthermore, Defendant states that she confessed to prevent others, who had nothing to do with the murders, from being charged. At no point in the interview did Defendant indicate that she confessed because the agents promised leniency or that her confession was in exchange for a lighter sentence. Nor do the agents state that they are offering Defendant a lesser sentence in exchange for her confession. Finally, the agents' recital of possible prison sentences does not render Defendant's statement involuntary."