With no explanation, chose the best option from "A", "B", "C" or "D". of Appellant’s consent to search, however, I do not believe that the majority affords sufficient weight to the coercive circumstances. In this regard, I depart from the view that the presence of police and legitimate police activity, specifically, securing the premises and placing Appellant in custody, do not implicate a coercive dynamic. Indeed, the Court has acknowledged that there is an element of coercion that exists in non-custodial interactions between law enforcement officers and citizens. See Commonwealth v. Strickler, 563 Pa. 47, 73, 757 A.2d 884, 898 (2000) (citing Commonwealth v. Jones, 474 Pa. 364, 371-72, 378 A.2d 835, 839 (1977)). Such element is enhanced when coupled with custody. See id.; see also Commonwealth v. Smith, 470 Pa. 220, 228, 368 A.2d 272, 277 (1977) (<HOLDING>). Of additional significance, in this case, the

A: recognizing that custody while not determinative in itself places a heavy burden in showing consent was voluntarily given and noting that custody when coupled with other coercive factors will normally necessitate the conclusion that the consent is not effective
B: holding that consent was freely and voluntarily given despite officers advisement that the police could get a search warrant if consent was not given
C: holding there is no consent as a matter of law where the consent was given under coercion
D: holding that warrantless search of defendants vehicle was legal because defendants consent was voluntary even through he was in police custody at the time of giving consent
A.