Minnesota Law Review
The United States Supreme Court has decided more cases involving the interrogation of juveniles than any other aspect of juvenile justice administration. 1 Although it has cautioned trial judges to be especially sensitive to the effects of youthfulness and immaturity on a defendant's ability to waive or to invoke her Miranda rights and to make voluntary statements, the Court has not mandated any special procedural protections for immature suspects. Instead, it endorsed the adult waiver standard - "knowing, intelligent, and voluntary" under the "totality of the circumstances" - to gauge the validity of a juvenile's waiver of Miranda rights. 2
Barry C. Feld, Juveniles' Competence to Exercise Miranda Rights: An Empirical Study of Policy and Practice, 91 Minn. L. Rev. 26 (2006), available at https://scholarship.law.umn.edu/faculty_articles/295.