According to the Empirical Research About Consent Searches

According to the empirical research about consent searches:

A) lower courts find that consent was voluntary in all but the most extreme cases .
B) lower courts are very willing to set consent searches aside when they find they were not voluntary
C) there are so few consent search cases that courts have had little opportunity to rule on the issue
D) judges are skeptical of consent searches and critical of the police in their opinions