Rules of evidence governing the admissibility of confessions have devel- oped gradually throughout the history of Anglo-American jurisprudence. Initially any confession was admissible regardless of the methods by which it was obtained. The basic consideration was that the evidence admitted be truthful and reliable. To protect the integrity of judicial proceedings, safeguards were later developed to insure the reliability of confessions by a determination of the voluntariness with which they were given. Courts have struggled with the problem of formulating a workable definition of voluntariness and have not yet developed a uniform substantive test.

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