In the case of State v. Moore, the Washington Court of Appeals ruled that:

"Here, the trial court found that the offer to Moore (to work with the police in exchange for a favorable recommendation to the prosecutor) was made post- Miranda, but not necessarily before or after the confession (which was also post- Miranda). A mere promise of leniency, without more, is not enough to invalidate a confession. State v. Riley, 19 Wn. App 289, 297-98, 576 P.2d 1311 (1978). At best, all that was promised here was a recommendation of leniency, which was offered in exchange for informant work, not for the confession. Because no evidence of coercion for a confession is in the record, the findings of fact support the conclusion that the offer did not invalidate Moore's confession.

Moore also claims that her statements were not voluntary because there was a "display of a weapon." Appellant's Br. at 10. The State responds that no testimony indicated that weapons were drawn while the officers spoke with Moore post- Miranda. The mere fact that the officers were armed, as officers usually are, was not in itself coercive."

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Failure to allow 17 year old to call his mother nullifies confession

In the case of People v. Westmorland, the Illinois Appellate court upheld the suppression of a 17 year old's confession, stating that:

"There were, however, some quite unsettling aspects of the interrogation. The officers made no attempt to locate defendant's parents when they arrested him and also denied his two requests during the interview to speak to his mother. Defendant was "immature" for his age and "wide-eyed." With defendant already vulnerable from the complete denial of parental contact, Galason raised his voice during the interview and said, "I don't give a shit if you go to jail or not." This was the conduct that, in the trial court's words, "terrified" defendant. Under the totality of the circumstances, which encompass both defendant's individual psychological makeup as well as the officers' conduct, we agree with the trial court that defendant's will was overborne."