In Rhode Island v. Innis, 446 U.S. 291 (1980), the Supreme Court defined the term "interrogation" for purposes of Miranda as including not only express questioning, "but also any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to illicit an incriminating response from the suspect." "A suspect's decision to waive his Fifth Amendment privilege against compulsory self-incrimination is made voluntarily absent evidence that his will was overborne and his capacity for self-determination was critically impaired because of coercive police conduct." State v. Dailey (1990), 53 Ohio St.3d 88, 559 N.E.2d 459, at paragraph two of the syllabus. In Rhode Island v. Innis, the Supreme Court determined that interrogation is not limited to actual questioning of a suspect by police but includes "express questioning or its functional equivalent." Id. at 300-301. The phrase "functional equivalent" was explained as including "any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect." Id. at 301. The Court noted that "the latter portion of this definition focuses primarily upon the perceptions of the suspect, rather than the intent of the police." Id. The Court concluded that "since the police surely cannot be held accountable for the unforeseeable results of their words or actions, the definition of interrogation can extend only to words or actions on the part of police officers that they should have known were reasonably likely to elicit an incriminating response." Id. at 301-302. In citing police practices that did not involve express questioning but which may amount to interrogation, the Court listed the use of lineups where a coached witness picks the suspect as the perpetrator; the so-called "reverse lineup" where the suspect is identified by a coached witness as the perpetrator of a fictitious crime, and the use of psychological ploys such as positing the guilt of the suspect as a fact; and minimizing the moral seriousness of the offense or casting blame for the offense on the victim or society. Id. at 299. The United States Supreme Court clarified that Miranda rights only come into play when a suspect in custody is subjected to either express questioning or its "functional equivalent," i.e., by words or actions on the part of police that they should know are "reasonably likely to elicit an incriminating response from the suspect." ( Id. at p. 301.) "That is to say, the term 'interrogation' under Miranda refers not only to express questioning, but also to any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect. The latter portion of this definition focuses primarily upon the perceptions of the suspect, rather than the intent of the police. This focus reflects the fact that the Miranda safeguards were designed to vest a suspect in custody with an added measure of protection against coercive police practices, without regard to objective proof of the underlying intent of the police. A practice that the police should know is reasonably likely to evoke an incriminating response from a suspect thus amounts to interrogation. But, since the police surely cannot be held accountable for the unforeseeable results of their words or actions, the definition of interrogation can extend only to words or actions on the part of police officers that they should have known were reasonably likely to elicit an incriminating response." ( Rhode Island v. Innis, supra, 446 U.S. at pp. 301-302.) The Court defined the phrase 'functional equivalent' of express questioning to include 'any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect. The latter portion of this definition focuses primarily upon the perceptions of the suspect, rather than the intent of the police.' However, 'any knowledge the police may have had concerning the unusual susceptibility of a defendant to a particular form of persuasion might be an important factor in determining' what the police reasonably should have known. Thus, custodial interrogation for purposes of Miranda includes both express questioning, and also words or actions that, given the officer's knowledge of any special susceptibilities of the suspect, the officer knows or reasonably should know are likely to 'have . . . the force of a question on the accused,' , and therefore be reasonably likely to elicit an incriminating response." The Court explained that "the special procedural safeguards outlined in Miranda are required not where a suspect is simply taken into custody, but rather where a suspect in custody is subjected to interrogation. 'Interrogation,' as conceptualized in the Miranda opinion, must reflect a measure of compulsion above and beyond that inherent in custody itself." (Innis, supra, 446 U.S. at p. 300.) The Court held in Innis that "the Miranda safeguards come into play whenever a person in custody is subjected to either express questioning or its functional equivalent," which the Court defined as "any words or actions on the part of the police (other than those normally attendant to arrest and custody) that the police should know are reasonably likely to elicit an incriminating response from the suspect." (Id. at pp. 300-301.)