People v. Nelson
California Supreme Court
266 P.2d 1008 (2012)
Fifteen-year-old Nelson, previously familiar with Miranda warnings from prior arrests, waived his rights and was questioned for nearly five hours about three burglaries including one where the elderly homeowner was found dead; during questioning he repeatedly asked to speak with his mother, was advised by his grandmother and brother not to take a polygraph and to wait for his mother or a lawyer, but continued talking with investigators and eventually wrote a confession to fatally striking the victim with a hammer.
Whether, in California, once a juvenile suspect has made a valid waiver of his Miranda rights, any subsequent assertion of the right to counsel or right to silence during questioning must be articulated sufficiently clearly that a reasonable police officer in the circumstances would understand the statement to be an invocation of such rights.