In the case of†State v Copley the Ohio†Court of Appeals ruled that the interrogator's statements to the†defendant that jail is not for everybody, that everybody deserves a second chance, and that counseling is a way for a person to get that second chance rise to the level of an implied promise of leniency.† However,the court found that when these statements were coupled with other factors they were insufficient to render the defendant's confession involuntary under the totality-of-circumstances test.