when, as in this case, the government relies on consent to justify a warrantless search, it bears the burden of proving by a preponderance of the evidence that the consent was voluntary. See United States v. Isiofia, 370 F.3d 226, 230 (2d Cir.2004). Voluntariness is determined by reference to the “ ‘totality of all the circumstances.’ ” Id. at 231 (quoting Schneckloth v. Bustamonte, 412 U.S. at 227, 93 S.Ct. 2041). While more than “mere acquiescence in a show of authority” is necessary to establish the voluntariness of a consent, United States v. Wilson, 11 F.3d 346, 351 (2d Cir.1993), the fact that a person is in custody or has been subjected to a display of force does not automatically preclude a finding of voluntariness, see United States v. Ansaldi, 372 F.3d 118, 129 (2d Cir.2004) (<HOLDING>). In considering a challenge to a district
holding the defendant voluntarily consented to a search of his bedroom based upon evidence that defendant 1 did not contest the fact that he had voluntarily given verbal consent to the search 2 did not appear to be nervous or scared and was cooperative with the officers 3 led officers to his bedroom and 4 was present for the search and did not indicate at any time that he wished to revoke his consent holding that defendants failure to withdraw consent to search for criminal activity in his home included the top floor because he did not withdraw his consent to search when he observed the officer go upstairs holding that defendants consent to search his person while on board an interstate bus was voluntary even though the police did not tell the defendant of his right to refuse consent holding that the defendants unlawful arrest in his hotel room rendered his subsequent consent to the search of his room invalid even though he signed a consent form allowing the search after his arrest because the government  completely failed to address whether there was a break in the causal relationship between the unlawful arrest and the subsequent search holding that use of guns to effectuate arrest and handcuffing of defendant did not render his consent to search his home involuntary