that the police informed him of his rights with regard to the DNA sample, Wyche was decidedly in police custody and subjected to police questioning before he consented to the search, and the police expressly or impliedly promised Wyche that he could exonerate himself with regard to a completely fabricated, yet ostensibly valid felony offense. These are all relevant factors under a totality-of-circumstances inquiry. See also Brown v. Brierley, 438 F.2d 954, 957-59 (3d Cir.1971) (pre-Schneckloth, extrinsic-fabrication decision holding that a police officer’s partial misrepresentation of purpose did not vitiate the voluntariness of the defendant’s consignment of a firearm to the officer for the purpose of sale); People v. Avalos, 47 Cal.App.4th 1569, 55 Cal.Rptr.2d 450, 453-57 (1996) (<HOLDING>). Therefore, when considering the type and
holding that where the police partially misrepresented the purpose of their search but possessed reasonable articulable suspicion if not fullblown probable cause that the defendant was distributing methamphetamines an extrinsic partial misrepresentation as to purpose did not negate consent holding that the dismissal of an indictment did not negate the presumption of probable cause holding that refusal to consent to search cannot support a finding of reasonable suspicion holding consent invalid when given under coercive circumstances in which police misrepresented that they had a warrant to search the home holding that the question of whether the police had reasonable suspicion and probable cause to make a warrantless search should be reviewed de novo