96 S.Ct. 820, 46 L.Ed.2d 598 (1976), the Court concluded that a consent to a search of a suspect’s car obtained while the suspect was in lawful custody was voluntary. The Court outlined the factors relevant to its analysis: There was no overt act or threat of force against Watson proved or claimed. There were no promises made to him and no indication of more subtle forms of coercion that might flaw his judgment. He had been arrested and was in custody, but his consent was given while on a public street, not in the confines of the police station. Moreover, the t and other courts have held that not all deception will invalidate a confession. Denmark v. State, 95 Fla. 757, 116 So. 757, 762 (1928); see also Hoffa v. United States, 385 U.S. 293, 301-02, 87 S.Ct. 408, 17 L.Ed.2d 374 (1966) (<HOLDING>); Brown v. Brierley, 438 F.2d 954, 955-57, 959
holding that defendants statements were admissible even though interviewing officer said youve got to tell me the truth holding that tapes made by fbi informant were admissible under  25112ed holding that defendants statements made to an informant were admissible even though the informant lied about his identity holding that a witness could testify about statements made to him by a police department investigator because the statements were an admission by partyopponent and were thus not excluded by the hearsay rule holding that states use of informant to obtain incriminating evidence from defendant about pending charges violated defendants sixth amendment right to counsel notwithstanding that state was also investigating other charges as to which the sixth amendment right to counsel had not attached