Read the following excerpt from a US court opinion:
```
237 F.Supp.2d 795, 801 (E.D.Mich.2003) (collecting cases). Thus, a consent to search that is obtained in violation of Miranda, that is, when it results from conversations initiated by the police after a suspect invokes his right to counsel or right to silence, is not necessarily violative of the Constitution. See ibid, (noting that “a consent to search obtained following a Miranda violation is not automatically tainted”). The Sixth Circuit has held that “where police simply fail to administer Miranda warnings, the admissibility of non-testimonial physical evidence derived from the uncounseled statements should turn of a statement mirror those used to assess the voluntariness of a consent to search. See Schneckloth v. Bustamonte, 412 U.S. 218, 227, 93 S.Ct. 2041, 36 L.Ed.2d 854 (1973) ; Guerra, 237 F.Supp.2d at 803. In this case,
```
What is the most suitable continuation to the opinion? Your options are:
A. holding that whether a consent to a search was in fact voluntary or was the product of duress or coercion express or implied is a question of fact to be determined from the totality of all the circumstances
B. holding that the reasonableness inquiry is based upon the totality of the circumstances in determining whether or not a search was reasonable
C. holding threat to obtain a search warrant if individual does not consent to a search is just one factor in deciding whether the totality of the circumstances supports a voluntary consent finding
D. holding it is a question of fact
E. holding that the government bears the burden of proving voluntary consent under the totality of the circumstances
Reply with [A, B, C, D, E] only.