of Appellant’s consent to search, however, I do not believe that the majority affords sufficient weight to the coercive circumstances. In this regard, I depart from the view that the presence of police and legitimate police activity, specifically, securing the premises and placing Appellant in custody, do not implicate a coercive dynamic. Indeed, the Court has acknowledged that there is an element of coercion that exists in non-custodial interactions between law enforcement officers and citizens. See Commonwealth v. Strickler, 563 Pa. 47, 73, 757 A.2d 884, 898 (2000) (citing Commonwealth v. Jones, 474 Pa. 364, 371-72, 378 A.2d 835, 839 (1977)). Such element is enhanced when coupled with custody. See id.; see also Commonwealth v. Smith, 470 Pa. 220, 228, 368 A.2d 272, 277 (1977) (<HOLDING>). Of additional significance, in this case, the
holding that consent was freely and voluntarily given despite officers advisement that the police could get a search warrant if consent was not given recognizing that custody while not determinative in itself places a heavy burden in showing consent was voluntarily given and noting that custody when coupled with other coercive factors will normally necessitate the conclusion that the consent is not effective holding there is no consent as a matter of law where the consent was given under coercion holding that warrantless search of defendants vehicle was legal because defendants consent was voluntary even through he was in police custody at the time of giving consent holding that custody alone has never been enough in itself to demonstrate a  consent to search