¶46. Both Connelly and Clappes support the proposition that some coercive or improper police conduct must exist in order to sustain a finding of involuntariness. However, both of these cases also recognize that police conduct does not need to be egregious or outrageous in order to be coercive. Rather, subtle pressures are considered to be coercive if they exceed the defendant’s ability to resist. Accordingly, pressures that are not coercive in one set of circumstances may be coercive in another set of circumstances if the defendant’s condition renders him or her uncommonly susceptible to police pressures.
But: waiver of Miranda rights must be knowing and intelligent as well as voluntary. Thus, even in the absence of police coercion — which forecloses a claim of involuntariness — a custodial statement from a suspect with an IQ of 54 and incapable of understanding her rights violated the knowing/intelligent waiver requirement. People v. Braggs, Ill. SCt No. 95350, 12/18/03.