With no explanation, chose the best option from "A", "B", "C" or "D". that the defendant was advised of his constitutional rights and whether that defendant knowingly waived them and voluntarily gave a statement. State v. Blakney (1982), 197 Mont. 131, 143, 641 P.2d 1045, 1051. Several factors can culminate in a totality of circumstances that render a confession involuntary. A confession extracted by any sort of threat or violence, by any direct or implied promises, however slight, or by the exertion of any improper influence has the potential to be involuntary. State v. Phelps (1985), 215 Mont. 217, 224, 696 P.2d 447, 451. Physical coercion, psychological coercion, inadequate Miranda warnings, and impermissible police practices are each factors weighed in a court’s consideration of undue influence. Brown v. Mississippi, 297 U.S. 278, 56 S.Ct. 461 (<HOLDING>); Payne v. Arkansas (1958), 356 U.S. 560, 78

A: holding that mental coercion led to an involuntary confession
B: holding that under elstad the first question that must be answered when determining whether a subsequent confession is tainted by an earlier confession is whether the initial confession was obtained in violation of the defendants fifth amendment rights  ie whether it was involuntary  or whether the confession was voluntary but obtained in technical violation of miranda 
C: holding that impermissible police procedures rendered confession involuntary
D: holding that physical brutality led to an involuntary confession
D.