These include lack of voluntariness, unconscionability, and a failure to disclose assets. Thirdly, appellant attacks the voluntariness of his consent to search. The participants' perceptions of the voluntariness and coercion of the confession were assessed via questionnaire. Nishikawa argued that voluntariness was an intrinsic element of the conduct required by section 401. Rather, voluntariness is a fact to be determined from all the circumstances surrounding the search. Judges employ various methods to determine voluntariness. Ratings of voluntariness in both the high-accountability and low-accountability groups show camera perspective bias. Voluntariness judgments varied as a function of the race of the suspect. Voluntariness is too important to fall before theoretical arguments about necessity and determinism.