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(1988) 88 Cr App R 285 (CA). The defendant sought to have his Confession excluded under s.76(2)(b) of Pace, on the grounds that it was elicited in circumstances which rendered it unreliable. He was a heroin addict in withdrawal and, he claimed, only confessed because he needed to get away to get another dose. However, the Court of Appeal held that anything said or done in s.76(2)(b) meant anything said or done by the police to the suspect. It did not apply to unfavourable circumstance which the suspect had brought on himself.

It is not entirely straightforward to reconcile this case with R v mc govern (1990), where the defendant's confession was excluded because it was made unreliable by her pregnancy and vomiting. McGovern's preganancy was no more something 'said or done' by the police than Goldberg's heroin addiction.