noncustodial situations and usually in custodial ones as well, unless government agents make threats or promises.” United States v. Kontny, 238 F.3d 815, 817(7th Cir.2001) (citing Frazier v. Cupp, 394 U.S. 731, 739, 89 S.Ct. 1420, 22 L.Ed.2d 684 (1969)). As the First Circuit has noted, trickery is not automatically coercion. Indeed, the police commonly engage in such ruses as suggesting to a suspect that a confederate has just confessed or that police have or will secure physical evidence against the suspect. While the line between ruse and coercion is sometimes blurred, confessions procured by deceits have been held voluntary in a number of situations. United States v. Byram, 145 F.3d 405, 408 (1st Cir.1998); see also United States v. Orso, 266 F.3d 1030, 1039(9th Cir.2001) (en banc) (<HOLDING>); Clanton v. Cooper, 129 F.3d 1147, 1158 (10th
holding that an administrator need not address each piece of evidence holding misrepresentation claim to be preempted holding negligent misrepresentation sufficient holding that an inspectors misrepresentation that a piece of evidence existed while reprehensible does not constitute coercive conduct holding that probation does not constitute a sentence