In People v. James (1977) 19 Cal.3d 99, the defendant was charged with burglary and robbery. He moved to suppress evidence of a stolen television set found in his house on the grounds that it was "obtained by an illegal search and seizure." (James, supra, 19 Cal.3d at p. 106.) In ruling that the trial court had properly denied defendant's suppression motion, our Supreme Court held: "Our guiding principles are well settled. Inasmuch as the search herein was conducted without a warrant, the burden was on the People to establish justification under a recognized exception to the warrant requirement. The People relied on consent, which constitutes such an exception. In that event, however, the People had the additional burden of proving that the defendant's manifestation of consent was the product of his free will and not a mere submission to an express or implied assertion of authority. The People may discharge the foregoing burdens by a preponderance of the evidence. (United States v. Matlock (1974) 415 U.S. 164, 177-178, fn. 14. . . .) The voluntariness of the consent is in every case 'a question of fact to be determined in the light of all the circumstances.'" (James, supra, at p. 106) Finding substantial evidence of voluntary consent, the James court upheld the trial court's denial of the defendant's motion to suppress the stolen television set. (Id. at p. 118.) The California Supreme Court found substantial evidence to support the trial court's implied finding that James voluntarily consented to a search of his house where: four armed officers knocked on James's door at night; one of the officers asked James to step outside, then handcuffed and placed him under arrest, informed him that they were conducting a robbery investigation, and asked if they could look in the house for items taken in the robbery. James said they could. (Id. at pp. 106-107.) The court rejected James's contention that the fact he was under arrest and in handcuffs rendered the consent involuntary as a matter of law. As the court explained, the fact that a defendant is in custody at the time he gives consent to search "is a circumstance which is of 'particular significance' but is 'not conclusive' in the determination of voluntariness." (Id. at p. 109.) Nor does the fact that a defendant is in handcuffs automatically render his consent to search involuntary. (Id. at p. 110.) Rather, these circumstances are "'to be considered along with all other circumstances bearing on the issue by the trial judge who sees and hears the witnesses and is best able to pass upon the matter.' Citation." (Ibid.) The court also rejected James's contention that his consent was merely submission to authority because armed officers who dramatically took him into custody confronted him at night. (James, supra, 19 Cal.3d at p. 110.) As the court explained: "The arresting officer neither held defendant at gunpoint, nor unduly detained or interrogated him; the officer did not claim the right to search without permission, nor act as if he intended to enter regardless of defendant's answer. Whether in some other setting the conduct of the officer might be deemed coercive is not the issue before us; rather, the precautions he took must be viewed in the light of his assignment on the evening in question, i.e., to apprehend a man who was suspected of armed robbery and burglary and was reportedly in possession of a handgun. 'Under these circumstances, to hold as a matter of law that the evidence was produced in response to an unlawful assertion of authority would seriously hamper officers in the reasonable performance of their duties." (Id. at p. 113.) In sum, the defendant entered three separately leased offices in a small office building and was convicted of three counts of burglary based upon his commission of theft in two offices and robbery in the third office. The Supreme Court rejected James's contention that he could not be sentenced separately for the burglary of each office, explaining, "defendant forcibly broke into three different rented premises occupied by tenants who had no common interest other than the fortuitous circumstance that they happened to lease office suites in the same commercial building. There is no doubt that if the premises had been located in three separate buildings defendant could have been punished for three separate burglaries; he is not entitled to two exempt burglaries merely because his victims chose the same landlord. If the rule were otherwise, a thief who broke into and ransacked every store in a shopping center under one roof, or every apartment in an apartment building, or every room or suite in a hotel, could claim immunity for all but one of the burglaries thus perpetrated. Nothing in the statute or case law on multiple punishment compels such an incongruous result." (Id. at p. 119.) The defendant said that when he gave his consent to search, he was standing alone with three armed officers around him. He contended these facts showed that his consent was a mere submission to authority because he was "under the total domination and control of the police." The court held that California cases that have invalidated findings on this ground have involved far more coercive circumstances or additional facts such as an illegal arrest or false claim of authority to search.