State v. Phillips
In State v. Phillips, 218 Wis. 2d 180, 196, 577 N.W.2d 794 (1998), the court considered numerous factors in determining whether the defendant's consent was coerced.
Specifically, the court noted that: the police did not use misrepresentation, deception, or trickery to coerce the defendant; the evidence failed to indicate that the police threatened, physically intimidated, or punished the defendant; the defendant was questioned and searched under non-threatening, cooperative conditions; and finally, the defendant neither acted annoyed nor objected to the police presence. See 218 Wis. 2d at 198-201.
The court then asserted that, when focusing on the defendant to determine voluntariness, courts should consider the defendant's age, intelligence, education, physical and emotional condition, and prior experience with the police. See 218 Wis. 2d at 202.