Elstad by holding that the deliberate, planned refusal to warn, followed by warnings after confession should be treated the same as the momentary, innocent failure to warn in Elstad; and 3) the Ohio Supreme Court’s ruling that defendant’s confession was voluntary resulted in a decision that was based on an unreasonable determination of facts presented in the state court proceeding, because the “admonition” that defendant should “cut a deal” was not simply… [read post]