In People v. Smith, the interrogating officers administered to the defendant a "Neutron Proton Negligence Intelligence Test" that pruportedly showed that the defendant had recently fired a gun. On appeal the defendant claimed that this was a coercive tactic. In the California Supreme Court's opinion they stated, "Police deception "does not necessarily invalidate an incriminating statement." ( People v. Maury (2003) 30 Cal.4th 342, 411, 133 Cal.Rptr.2d 561, 68 P.3d 1.) Courts have repeatedly found proper interrogation tactics far more intimidating and deceptive than those employed in this case. (See, e.g., Frazier v. Cupp (1969) 394 U.S. 731, 739, 89 S.Ct. 1420, 22 L.Ed.2d 684 [officer falsely told the suspect his accomplice had been captured and confessed]; People v. Jones (1998) 17 Cal.4th 279, 299, 70 Cal.Rptr.2d 793, 949 P.2d 890 [officer implied he could prove more than he actually could]; People v. Thompson (1990) 50 Cal.3d 134, 167, 266 Cal.Rptr. 309, 785 P.2d 857 [officers repeatedly lied, insisting they had evidence linking the suspect to a homicide]; In re Walker (1974) 10 Cal.3d 764, 777, 112 Cal.Rptr. 177, 518 P.2d 1129 [wounded suspect told he might die before he reached the hospital, so he should talk while he still had the chance]; People v. Watkins (1970) 6 Cal.App.3d 119, 124-125, 85 Cal.Rptr. 621 [officer told suspect his fingerprints had been found on the getaway car, although no prints had been obtained]; and Amaya-Ruiz v. Stewart (9th Cir.1997) 121 F.3d 486, 495 [suspect falsely told he had been identified by an eyewitness].) Indeed, at least one Court of Appeal has approved of the particular practice used in this case. ( People v. Parrison (1992) 137 Cal.App.3d 529, 537, 187 Cal.Rptr. 123 [police falsely told suspect a gun residue test produced a positive result].)

After examining the circumstances surrounding the "Neutron Proton Negligence Intelligence Test," it does not appear that the tactic was so coercive that it tended to produce a statement that was involuntary or unreliable.