With no explanation, chose the best option from "A", "B", "C" or "D". confessions were given under conditions so oppressive that his statements must be deemed involuntary. In Arizona, confessions are presumed to be involuntary, and the State has the burden of proving otherwise. See State v. Scott, 177 Ariz. 131, 136, 865 P.2d 792, 797 (1993). In ruling on voluntariness, a court must examine the totality of circumstances. See id.; State v. Arnett, 119 Ariz. 38, 42, 579 P.2d 542, 546 (1978). Although “personal circumstances, such as intelligence and mental or emotional status, may be considered in a voluntariness inquiry, the critical element ... is whether police conduct constituted overreaching.” State v. Stanley, 167 Ariz. 519, 524, 809 P.2d 944, 949 (1991); see also Colorado v. Connelly, 479 U.S. 157, 167, 107 S.Ct. 515, 522, 93 L.Ed.2d 473 (1986) (<HOLDING>); Scott, 177 Ariz. at 136, 865 P.2d at 797. A

A: holding that coercive police activity is a necessary predicate to an involuntariness finding
B: holding that actual intent to defraud is not necessary to finding of constructive fraud
C: holding in marshak underscores that unlawful acts are a necessary predicate to an action for civil conspiracy
D: holding motion for attorneys fees was necessary predicate
A.