Tobias v. Arteaga
Coerced confession claims cannot be asserted under a fabrication of evidence theory; coercive interrogation exists when officer’s tactics undermine suspect’s ability to exercise free will, rendering statements involuntary; court denies qualified immunity on Fifth Amendment claim that officers continued to question juvenile after he invoked right to silence, requested attorney, and that officers threatened juvenile with harsher penalties if he continued to “lie” and did not confess; juvenile’s statement, “Could I have an attorney?