Can Juvenile Waive Right to Counsel Without First Consulting With Parent, Adult Custodian or Lawyer?
When Interrogated in Police Custody Prior to Filing of a Juvenile Complaint
8th District Court of Appeals (Cuyahoga County)
ISSUE: Does language in R.C. 2151.352 indicating that a child has a right to counsel at "all stages of the proceedings" in a delinquency case require that a juvenile in police custody prior to the filing of a delinquency complaint must be allowed to consult with a parent, guardian, adult custodian or attorney before the juvenile can validly waive his or her right to counsel during his interrogation?