In Arthur v. Commonwealth, 24 Va. App. 102, 105, 480 S.E.2d 749 (1997), the police prepared "'dummy' reports" showing that a fingerprint and hair found at the scene of a murder matched the defendant's. A police detective confronted the defendant with the fake reports, but he continued to deny that he had been at the scene of the murder. He did confess, however, after the detective told him that the police and the victim's family believed that he loved the victim and that the killing was unintentional, and that the victim's family wanted to know what had happened.
On appeal, the defendant urged the court to "draw a 'bright line' where false documents are used." Id. at 107.
The court rejected that approach in favor of the totality of the circumstances test, and concluded that the use of the fabricated fingerprint and DNA reports "did not overcome the defendant's will or critically impair his capacity for self-determination." Id. at 108.