State v. Graham, 223 N.C. App. 150 (Oct. 16, 2012)

In this child sexual abuse case, the defendant’s confession was not involuntary. After briefly speaking to the defendant at his home about the complaint, an officer asked the defendant to come to the police station to answer questions. The court rejected the defendant’s argument that his confession was involuntary because he was given a false hope of leniency if he was to confess and that additional charges would stem from continued investigation of other children. The officers’ offers to “help” the defendant “deal with” his “problem” did not constitute a direct promise that the defendant would receive a lesser or no charge should he confess. The court also rejected the defendant’s argument that the confession was involuntary because one of the officers relied on his friendship with the defendant and their shared racial background, and that another asked questions about whether the defendant went to church or believed in God. Finally, the court rejected the defendant’s argument that his confession was involuntarily obtained through deception.

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