phone call for him to his girlfriend. Detective Wolcott noted that he only “believed” Martin’s girlfriend was trying to arrange a visit. Detective West stated that they could “make arrangements for visits” between Martin and his girlfriend. Martin claims that this promise induced his confession in violation of U.S. Supreme Court precedent holding that a confession “must not be extracted by any sort of threats or violence, nor obtained by any direct or implied promises, however slight, nor by the exertion of any improper influence.” Bram v. U.S., 168 U.S. 532, 542-43, 18 S.Ct. 183, 42 L.Ed. 568 (1897). This standard, however, is not the absolute yardstick in assessing the voluntariness of a confession. See Arizona v. Fulminante, 499 U.S. 279, 285, 111 S.Ct. 1246, 113 L.Ed.2d 302 (1991) (<HOLDING>). The correct test is whether, based on a
holding that if a state case explicitly states that the state standard is more favorable to the defendant than the federal standard the federal claim is considered adjudicated below when the state standard is applied holding that even if the standard for waiver is clear the standard was not met holding that appellate court could not review the sufficiency of the evidence  based on a particular legal standard because that standard was not submitted to the jury and no party objected to the charge on this ground or requested that the jury be charged using this standard holding that this standard from bram does not state the standard for determining the voluntariness of a confession under current precedent holding that jackson standard is only standard to use when determining sufficiency of evidence