to search the house, and, while appellant was handcuffed in the back of the patrol car, the officers told him that if he did not consent, his mother and young son would be required to vacate the house while the officers secured the residence, despite the officers having no basis for doing so. After this threat was made, appellant spoke to his mother; appellant then agreed to sign the written consent to search. The officers’ threats to remove appellant’s family from the residence are what lead appellant ultimately to consent to a search of his residence. Such antagonistic action by the police against a suspect’s family is a factor which significantly undermines the voluntariness of any subsequent consent given by the suspect. See United States v. Ivy, 165 F.3d 397, 403-04 (6th Cir.1998) (<HOLDING>); United States v. Bolin, 514 F.2d 554, 560-61
holding that a district court did not clearly err in finding consent where two agents testified that the defendant orally consented but the defendant denied having orally consented and would not sign a written consent form holding consent invalid where defendant threatened by officer that everyone in the house would go to jail if he did not sign consent form holding consent invalid where defendant signed consent form while undergoing custodial interrogation and only after he had been impliedly threatened that his girlfriend would be arrested if he did not sign holding consent not voluntary where police threatened to arrest defendants girlfriend if he refused to sign consent form holding waiver to search invalid when individual was implicitly threatened with illegal detention if he did not consent