1070 (10th Cir.1997); United States v. Fadel, 844 F.2d 1425, 1430-31 (10th Cir.1988). 3 . The Quaintances argue that sincerity wasn't at issue in Meyers and Thiry and urge us to consider those cases’ statements about the applicable standard of review to be dicta. Sincerity, they say, is best viewed as a “constitutional fact” meriting "independent” or de novo review. See Bose Corp. v. Consumers Union of U.S., Inc., 466 U.S. 485, 505-11 & n. 27, 104 S.Ct. 1949, 80 L.Ed.2d 502 (1984). Though RFRA offers statutory, not constitutional, protection of religious freedom, the Quaintances note that we have extended the constitutional fact doctrine to certain findings in RFRA cases and subjected them to plenary appellate review. See United States v. Friday, 525 F t. 445, 88 L.Ed.2d 405 (1985) (<HOLDING>). Sincerity, meanwhile, lacks the legal flavor
holding that the relevant time of inquiry is the date of the filing of the complaint holding state must prove voluntariness of confession beyond a reasonable doubt holding that under elstad the first question that must be answered when determining whether a subsequent confession is tainted by an earlier confession is whether the initial confession was obtained in violation of the defendants fifth amendment rights  ie whether it was involuntary  or whether the confession was voluntary but obtained in technical violation of miranda  holding the determination of the voluntariness of a confession is a determination uninfluenced by the truth or falsity of the confession holding assessments of credibility and demeanor are not crucial to deciding voluntariness of confession relevant inquiry is whether the techniques for extracting the statements  are compati ble with a system that presumes innocence and assures that a conviction will not be secured by inquisitorial means