In People v. Gennings, 808 P.2d 839 (Colo. 1991) the examiner's use of threats and a "soft technique" were determined by the court to be psychologically coercive. However, the examiner's conduct did not play so significant a role in overbearing the defendant's will as to have caused the defendant's statement to be involuntary. The supreme court concluded that the "soft technique," absent the outright threats, did not constitute improper coercion.