In a criminal voir dire arising from sexual assault and sexual interference charges, the court considered whether oral and written statements made during a police interview were voluntary.
The accused argued that lack of sleep, emotional distress, and forceful police questioning rendered the statements involuntary.
Applying the confessions rule and the framework governing oppressive circumstances, the court found the interview was relatively brief, the accused remained lucid, had access to coffee, declined counsel, and his will was not overborne.
Both the verbal statements and the written apology were ruled voluntary and admissible at trial.
