Whether a complainant in a sexual case is a 'person in authority' for the voluntariness rule depends on the subjective perception of the accused, not the complainant's objective capacity to influence prosecution. A complainant who has no apparent authority over the accused and is not perceived by the accused as capable of influencing prosecution is not a person in authority. Police advice to a complainant to replicate and record admissions previously made is not improper trickery where the conversation does not infringe the accused's right of choice whether to speak to police.
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