Consent to Search under Threat of Search Warrant

To be valid, consent to search must be voluntary. Is consent voluntary when given after an officer thrreatens to obtain a search warrant if consent is withheld? Generally, yes. See State v. Kuegel, 195 N.C. App. 310 (2009) (consent to search was given voluntarily even though officer said that if consent was denied he "would leave two detectives at the residence and apply for a search warrant"); State v. Fincher, 309 N.C. 1 (1983) (the defendant consented voluntarily where he "was told that although he did not have to give permission to search, if he refused the officers would obtain a search warrant and conduct a search"); United States v. Comstock, 531 F.3d 667 (8th Cir. 2008) (finding that under the totality of the circumstances, the defendant voluntarily consented even though "the officers apparently stated that if [he] refused to consent to the search they would obtain a search warrant, during which time [he] would continue to be detained in handcuffs for an additional two hours"); United States v. Garcia, 890 F.2d 355 (11th Cir. 1989) ("The agents simply told Garcia that they would secure the house and attempt to obtain a search warrant if he refused consent. We find nothing in this statement which would indicate that the agents were trying to do anything more than lawfully request Garcia's permission to search."). Of course, voluntariness is determined under the totality of the circumstances, and there is some out-of-state authority suggesting that a threat to obtain a search warrant is a [...]