his past sexual history as part of the program. However, the hospital promised that any information disclosed during treatment would remain confidential. The petitioner confessed to new sex crimes during treatment, which the hospital disclosed to the court. The court thereafter sentenced the petitioner to an extended period of imprisonment, in part because of the petitioner’s confessions of past criminal sexual activity. We held that the petitioner’s confessions were obtained involuntarily because he was required to divulge his past criminal history under the promise that any disclosures would remain confidential. Id. at 1465-66. Pens is consistent with several decisions from our court, as well as our sister circuits. See, e.g., United States v. Walton, 10 F.3d 1024, 1031 (3d Cir.1993) (<HOLDING>); United States v. Harrington, 923 F.2d 1371,
holding that payment made in reasonable belief that it was required by an insurance contract was involuntary holding that plaintiffs testimony in employment discrimination case about statement made to her by manager was inadmissible hearsay because it included statement made by others who were unidentified holding that the defendants statement was involuntary because it was made during a court ordered mental examination and a state statute provided that such statements would remain confidential holding that trial counsel was not ineffective when he failed to introduce defendants prior consistent statement statement was not admissible because it was made after defendant had been arrested clearly not a time when the effect of the statement could not have been foreseen holding that the defendants statement was involuntary because federal officer made a direct promise of confidentiality