Cited by

Two years later, citing to Dexter, the supreme court explained that if a prosecutor “plan[s] fro m the 9 inception to call the witness fo r the purpose of introducing he r prior statements, the prosecutor [is] guilty of misusing the rule to expose the jury to hearsay under the theory of impeachment.” State v. Anderson

See Lynumn v. Illinois, 372 U.S. 528, 531, 534, 83 S. Ct. 917, 919, 920 (1963) (concluding that a confession was involuntary where police told the defendant, who had no previous experience with the criminal justice system, that if she did not cooperate she would lose financial aid for her children, her children might be taken from her, and she may never see them again); d 63, 65 (Minn. 1980) (noting that “a promise to free a relative in exchange for a confession may render a confession inadmissi

the defendant argued that his confession was involuntary because investigating officers promised to release his female friend if he confessed.

6 . (stating that the prosecutor did not misuse the rules of evidence by impeaching a state witness with a statement given to police because it "appears that the prosecutor was not sure the witness would deny defendant’s guilt when she took the stand”).

State v. (Kevin) Anderson

*811 Subsequent decisions established, however, that, as we put it in State v. (Kevin) Anderson, “courts do not mechanically hold confessions involuntary just because a promise has been involved.” Rather, the approach courts have taken is to “look to the totality of the circumstances, considering all the factors bearing on voluntariness.” Id.

See United States v. Cammisano, 599 F.2d 851, 856 (8th Cir.1979); (promise to free a relative in exchange for a confession may render a confession involuntary).

However, courts do not mechanically hold confessions involuntary just because a promise has been involved.”

(the fact that defendant was told that any cooperation would be brought to the trial court’s attention did not render confession “involuntary”); (promise to release defendant pending formal charging and to summon him rather than arrest him on a warrant did not render defendant’s confession “involuntary”); (promise to a defendant that a female friend would be released from jail if he gave a written statement did not render his confession “involuntary”); State v. Biron, 266 Minn. 272 , (holding “i

we held that a promise to a defendant that a female friend would be released from jail if he gave a written statement did not render his confession involuntary, stating: It is true that a promise to free a relative in exchange for a confession may render a confession inadmissible.

the defendant was promised that a female friend would be released from jail if he gave a written statement.