In State v. Von Dohlen, 322 S.C. 234, 471 S.E.2d 689 (1996), the police showed the defendant a "composite sketch" of himself to make him think they had an eyewitness to the murder he was being questioned about.

In fact, the "composite sketch" was drawn by a police artist looking at the defendant through a one-way window in the interrogation room.

The defendant also was shown spent shell casings that the police falsely told him had been found at the crime scene.

The defendant maintained his innocence after being confronted with those items, but confessed about an hour and a half later.

The court agreed with the defendant that the police tactics were "reprehensible." Id. at 243.

Without drawing any distinction between written and verbal misrepresentations of the evidence, the court applied the totality of the circumstances test, and concluded that "the present record simply does not sustain the defendant's claim that his will was overborne, so as to render his confession involuntary." Id.