Juvenile Miranda Warnings

Abstract

The American Bar Association, via its newly adopted policy, seeks fundamental changes in procedural justice with respect to juvenile Miranda warnings. It calls for understandable Miranda warnings to educate youth in custody regarding the relevant Constitutional protections. In surveying prosecutors and public defenders, the authors collected 293 juvenile Miranda warnings that are intended specifically for youthful offenders. Length and reading levels were analyzed and compared to an earlier survey. Nearly two thirds (64.9%) of these warnings were very long (> 175 words), which hinders Miranda comprehension. In addition, most juvenile warnings (91.6%) require reading comprehension higher than a 6th-grade level; 5.2% exceed a 12th-grade reading level. Combining across two surveys, more than half of juvenile Miranda warnings are highly problematic because of excessive lengths or difficult reading comprehension. However, simple and easily read Miranda components were identified that could be used to improve juvenile advisements. Breaking new ground, Miranda waivers were examined for both juveniles and their parents/interested adults. Interestingly, most juvenile versions emphasized waivers in positive terms (e.g., “an opportunity”) and downplayed the potential for negative consequences.

Keywords

Miranda Miranda warnings Miranda waivers juvenile suspects 5th Amendment protections

In Miranda v. Arizona (1966), the Supreme Court of the United States held that any time a criminal suspect is taken into police custody, the suspect must be given a Miranda advisement or some other fully effective means. Regarding the content, it affirmed the following:

He must be warned prior to any questioning that he has the right to remain silent, that anything he says can be used against him in a court of law, that he has the right to the presence of an attorney, and that if he cannot afford an attorney one will be appointed for him prior to any questioning if he so desires. Opportunity to exercise these rights must be afforded to him throughout the interrogation. (p. 479)

Fragments of the Miranda content have entered the popular consciousness via innumerable police dramas during the course of the last four and a half decades. Its five components (i.e., Right to Silence, Risks of Waiving Silence, Right to Counsel, Provision of Free Legal Services, and Assertion of Rights at Any Time) must be conveyed in “clear and unequivocal language” (Miranda v. Arizona, 1966, p. 468). Opening the flood gates to different versions, the Supreme Court affirmed in California v. Prysock (1981) that “no talismanic incantation was required to satisfy its strictures” (p. 359). As a result, hundreds of different warnings were proliferated (Rogers, Hazelwood, Harrison, Sewell, & Shuman, 2008), often replete with complex terms and dense phraseology well beyond the expected comprehension of most juvenile suspects, to say nothing of those who may also be mentally disordered, cognitively disabled, or otherwise challenged with respect to the English language (Rogers, 2008, 2011).

On February 11, 2010, the American Bar Association adopted a new policy calling for “the development of simplified Miranda warning language for use with juvenile arrestees.” In a report proposing and recommending adoption of the policy, Hynes (2010) presented evidence that complex language and difficult reading levels are major obstacles to Miranda comprehension for most juvenile offenders, and that these pervasive problems are further magnified when warnings are applied to preteen suspects. The report looked with approval upon modified Miranda warnings that emphasize either a comprehensive understanding or easily-understood, concise language.

Hynes (2010) cites State v. Benoit (1985), a decision by the New Hampshire Supreme Court that recommends model language for contributing to a juvenile arrestee’s comprehensive understanding of Miranda rights. The Benoit warning is distinguished from most other Miranda warnings by its provision of two explicit choices for either exercising or relinquishing Miranda rights. It emphasizes Constitutional safeguards such as “you will not be punished for deciding to use these rights” (p. 22) and “things you say to the lawyer cannot be used in court to prove what you may have done” (p. 23). Two structural features of the Benoit warning deserve comment. On one hand, it is written at an easily read level, that is, a Flesch-Kincaid grade level (i.e., minimum level for > 75% comprehension) of 4.4. On the other, its lengthy efforts to explain the rights in question result in a combined Benoit warning and waiver of a daunting 713 words.

In contrast to the prolixity of Benoit, Rogers and his colleagues (Rogers, Hazelwood, Sewell, Shuman, & Blackwood, 2008) proposed simplified warnings that emphasize concise wording while maintaining easy reading comprehension. The simplest version proposed by Rogers, Hazelwood, Sewell, et al. (2008) is 75 words, written at a Flesch-Kincaid grade level of 2.0. Even when a parent (or “interested adult”) provision is added, the numbers increase only to 102 words at a grade level of 2.3. These contrasting views—Benoit and Rogers, Hazelwood, Sewell, et al.—represent two very different approaches to improving youthful suspects’ comprehension of juvenile Miranda warnings.

Helms (2007) contacted state and federal agencies and received 21 juvenile Miranda warnings. When examining their Flesch-Kincaid reading levels, he found juvenile Miranda warnings/waivers were written at a substantially higher grade level (M = 8.11, SD = 1.94) than general warnings (M = 6.72, SD = 1.24), producing a large effect size (Cohen’s d = 0.95). He also reported a large range in average reading levels across individual Miranda components from 3.89 for Right to Silence to 9.48 for Free Legal Services.

Rogers, Hazelwood, Sewell, et al.’s (2008) survey identified 122 juvenile Miranda warnings and also found remarkable variations in the lengths and reading levels of these warnings. For example, the Right to Silence component varied from 7 to 69 words with Flesch-Kincaid reading levels ranging from the first grade of elementary school to the third year of college. Compared to Helms (2007), three of the five Miranda components differed by more than 0.5 grade level, each being higher in the Rogers, Hazelwood, Sewell, et al. survey: Right to an Attorney (8.81 vs. 7.87), Free Legal Services (10.36 vs. 9.48), and Continuing Rights (8.83 vs. 7.98). Although the issue was not addressed by Helms, many juvenile Miranda warnings include an additional component about seeking input from a parent, guardian, or even an interested adult. The typical difficulty of this component is reflected in its challenging reading levels (grade M = 10.79, SD = 3.08).

The survey by Rogers, Hazelwood, Harrison, et al. (2008) revealed the efforts of a minority of juvenile warnings at clarifying terms and emphasizing Constitutional safeguards. For clarification purposes, 3.3% defined the judge’s role, with about half of these (1.6%) employing a sport analogy (e.g., “like an umpire”). Concerning emphasis on safeguards, 4.1% affirmed that an exercise of rights could not be used as evidence of guilt. As with Benoit, a small number of juvenile warnings attempted to serve an educative function in explaining rather than simply stating Miranda components.

Legal Developments

Most jurisdictions are not required to have a specific warning for juvenile suspects, although the Supreme Court of the United States has long recognized that “parents possess what a child lacks in maturity, experience, and capacity for judgment required for making life’s difficult decisions” (Parham v. J. R., 1979, p. 602). Indeed, the Court was able to articulate the enhanced needs of juvenile suspects more than six decades ago when observing, “that which would leave a man cold and unimpressed can overawe and overwhelm a lad in his early teens” (Haley v. Ohio, 1948, p. 600). Although the Court has steadfastly declined to mandate for custodial juvenile suspects such Miranda-oriented accommodations as simplified warnings, parental notification, or other adult involvement, it recently opined on the allegedly custodial nature of a child’s interrogation and the extent to which juvenile status invokes not only the Constitutional rights traditionally embodied by Miranda v. Arizona (1966) but also statutory provisions that offer additional support for juvenile arrestees. Writing the majority opinion for J. D. B. v. North Carolina (2011), Justice Sotomayor declared:

It is beyond dispute that children will often feel bound to submit to police questioning when an adult in the same circumstances would feel free to leave. Seeing no reason for police officers or courts to blind themselves to that commonsense reality, we hold that a child’s age properly informs the Miranda custody analysis. (pp. 2398-2399)

This opinion emphasized that “children cannot be viewed simply as miniature adults” (p. 2404) because of fundamental differences in breadth of experience, reactions to authority, and maturity of judgment. Although the Court was not prepared to go so far as to insist “that a child’s age will be a determinative, or even a significant, factor in every case” (p. 2406), it did conclude regarding the unique nature of children’s responses to interrogation that “courts can account for that reality without doing any damage to the objective nature of the custody analysis” (p. 2403). Specifically, the Court ruled that “a child’s age properly informs the Miranda custody analysis” (p. 2399).

The most frequently cited case regarding the Miranda rights of juvenile arrestees, Fare v Michael C. (1979), refers repeatedly to a “totality of the circumstances” approach in weighing Miranda waiver sufficiency. Fare specifically considers “age, experience, education, background, and intelligence” (p. 725), but Fare reflects at every turn the presumption that the interrogation in question is “custodial.” Now, however, in J.D.B. v. North Carolina (2011), the Supreme Court of the United States has paved the way for trial courts to extend its age and disability-sensitive test in Fare to the determination of juvenile custodial status itself.

Approximately 12 states have already moved beyond Constitutional minima to establish further protections for juvenile suspects (Larson, 2003). Examples of these protections (see King, 2006) include (a) provision of counsel to the child before a waiver can be considered valid, (b) access to the advice of an adult who does not possess interests adverse to those of the child, and (c) meaningful consultation with an adult who must join the child in any subsequent waiver.

These initiatives reflect a hard-won practical understanding that “reliance upon parental or guardian involvement leads to its own troublesome issues where the adult’s interests may not coincide with those of the juvenile suspect” (Rogers, Hazelwood, Sewell, et al., 2008, p. 65). The Supreme Court in Parham v. J. R. (1979) conceded as much when it acknowledged that while “historically [the law] has recognized that natural bonds of affection lead parents to act in the best interests of their children . . . experience and reality may rebut what the law accepts as a starting point” and that parents “may at times be acting against the interests of their children” (p. 602).

Key to providing for mature assistance while sidestepping parental conflicts of interest—and correspondingly undue influence—is the mandated availability of what is termed an “interested adult” to help children “grasp the meaning of their rights and the implications of waiving them” (Greene, Heilbrun, Fortune, & Nietzel, 2007, p. 397). The role of the “interested adult”—cited with approval by the Supreme Court as early as Gallegos v. Colorado (1962)—typically requires an “opportunity for the adult to explain the rights and significance of a waiver to the juvenile,” although it should be noted that privacy mandates are highly variable “with officers sometimes encouraging private, thorough conversation, and other times hovering and interrupting to inquire if the consultation is finished” (Oberlander & Goldstein, 2001, p. 462.

Despite the lack of recent appellate innovation in this regard, the legal community cannot be characterized as satisfied with the current jurisprudential landscape for juvenile Miranda issues. As noted in the opening paragraph, the American Bar Association has found it necessary to call as a matter of official policy for the development of simplified Miranda warning language for use with juvenile arrestees (ABA Division for Media Relations and Communication Services, 2010; American Bar Association, 2010; American Bar Association Criminal Justice Section, 2010; Hynes, 2010). The impetus for this policy was based primarily on the American Bar Association’s review of research conducted by Rogers, Hazelwood, Sewell, et al. (2008) that established the astonishing variability and complexity of juvenile Miranda warnings that in many cases actually require higher levels of reading comprehension than their adult counterparts within the same jurisdiction.

Miranda Comprehension and Reasoning

Miranda comprehension for juvenile offenders has focused on Grisso’s (1998) Miranda instruments and their forthcoming revision, the Miranda Rights Comprehension Instruments–II (Goldstein, Zelle, & Grisso, in press). In their analysis of 152 juvenile defendants, Viljoen, Zapf, and Roesch (2007) found a clear link between age and impaired Miranda comprehension: 11-13 years (58.0% impaired), 14-15 years (33.3% impaired), and 16-17 years (7.8% impaired). This relation of age to impaired Miranda comprehension has been clearly established in both offender (Colwell et al., 2005; Riggs-Romaine, 2008) and community (McLachlan, Roesch, & Douglas, 2010; Woolard, Cleary, Harvell, & Chen, 2008) samples. Closely aligned with age, maturity also plays an important role in Miranda comprehension (Cauffman & Steinberg, 2000).

The effects of intellectual deficits on Miranda comprehension of juvenile offenders have been clearly demonstrated from Grisso’s (1981) seminal research through to more recent studies. Goldstein, Condie, Kalbeitzer, Osman, and Geier (2003) found that male offenders with low intelligence (M = 69.43) lagged far behind those with average abilities (M = 96.57) in Miranda understanding at each age level. Predictably, verbal intelligence (VIQ) is more closely related to Miranda comprehension than performance intelligence (PIQ). For example, Colwell et al. (2005) found substantial correlations for VIQ with Miranda recall (.56) and vocabulary (.60) that were not evident for PIQ (.25 and .26, respectively).

For Miranda reasoning, Grisso (1981) found that juvenile offenders often displayed impaired reasoning based on false premises. Concerning the Right to Silence, 61.8% did not understand that it constituted a Constitutional safeguard, whereas 55.3% falsely believed the court could revoke this right on its own accord (Table 20, p. 123). Interestingly, the Right to Silence has consistently been determined to be the most vulnerable to misunderstanding. For example, Viljoen et al. (2007) found that at least one third of juvenile offenders below the age of 16 failed to grasp this concept. When Miranda reasoning is combined with comprehension, the age-related pattern is very troubling with regard to compromised abilities among juvenile offenders: 80.0% (11-13 years), 58.8% (14-15 years), and 33.3% (16-17 years).

Current Study

The first main objective of the current study is to further investigate the findings of Rogers, Hazelwood, Sewell, et al. (2008) regarding reading levels, lengths, and contents of juvenile Miranda warnings. The second main objective is a detailed analysis of juvenile Miranda waivers. Although the Supreme Court of the United States has specified that the police are “not required to obtain a waiver” before commencing a custodial interrogation (Berghuis v. Thompkins, 2010, p. 2264), most juvenile Miranda advisements include waivers. Therefore, the comprehension and understanding of juvenile waivers may affect (a) overall comprehension of the warning per se (e.g., cognitive overload) and (b) subsequent decision making (e.g., contextualizing information in favor of one option). In seeking to contextualize the child’s decision, do juvenile waivers emphasize only the relinquishment of Miranda rights in positive terms, such as the “opportunity” to speak or “privilege” of speaking? Alternatively, do they provide a more balanced perspective by addressing as well the value of exercising of these rights (e.g., maintaining Constitutional safeguards)?

An ancillary objective of the current study entails an analysis of parental waivers that are sometimes included in the juvenile advisement process. In addition to a focus on length and reading level, a content analysis is also performed.

Method

Survey

Prior surveys (Rogers, Harrison, Shuman, Sewell, & Hazelwood, 2007; Rogers, Hazelwood, Harrison, et al., 2008) focused primarily on what can be characterized as “general” Miranda warnings—that is, those that have no age restrictions. Removing duplicates from the same jurisdictions, these surveys yielded 945 general Miranda warnings from 888 jurisdictions. Although juvenile Miranda warnings were explicitly requested in these surveys, the total number received was much lower at 122 warnings of the 888 jurisdictions (13.7%) providing general waivers.

For the current study, we attempted to contact prosecutors and defense counsel in each of the 3,068 counties in the United States via mailed surveys. We relied primarily on two databases containing information on United States county jurisdictions: (a) the National Association of Counties (NACo; available at http://www.naco.org) and (b) United States Counties (U.S. Counties; available at http://www.us-counties.com) to secure the names and addresses of district attorneys and public defenders. Letters were sent to the prosecutors in each county and, where available, the public defender’s office.

The letter requested “copies of the juvenile Miranda warnings used by law enforcement officers in your county” and referred to the fact that earlier research had identified juvenile warnings that required more than a high school reading level of comprehend. Respondents were given three options for responding: a stamped and addressed envelope, a dedicated fax number, or a designated Miranda e-mail address.

Analysis of Juvenile Miranda Warnings

The juvenile Miranda material is composed of warnings, waivers, and ancillary material (e.g., information about the county or other legal rights presented at the same time). This material and the parental waivers were analyzed individually using commercial software from Micro Power and Light, using their Readability Plus program (http://www.micropowerandlight.com/rdplus.html). This program provides readability calculations. For the current article, we utilized the Flesch-Kincaid and Flesch Reading Ease (see below) to provide grade-level estimates.

Flesch-Kincaid

The Flesch-Kincaid (Flesch, 1950) is the most widely accepted estimate of grade level. It is important to note its criterion for establishing grade levels is set at 75% or greater comprehension; typically one to two grades higher are needed for full (90% to 100%) comprehension (DuBay, 2004). The Flesch-Kincaid correlates well with standardized reading tests and is commonly used in Miranda-related research (e.g., Eastwood, Snook, & Chaulk, 2010; Helms, 2003, 2007) and the study of informed consent more generally (Paasche-Orlow, Taylor, & Brancati, 2003).

Flesch Reading Ease

The Flesch Reading Ease (Flesch, 1948) estimates what proportion of the adult population is likely to understand the reading material. Commonly used to evaluate clinical measures (Beckman & Lueger, 1997), it provides convenient categories for summarizing data regarding the requisite level of education (e.g., 0-30 for college graduate, 31-50 for some college).

Content analysis

This investigation utilized the same subcategories as Rogers, Hazelwood, Harrison, et al. (2008) for classifying different content for specific juvenile Miranda components. Because the previous study had not included Miranda waivers in the content analysis, major categories needed to be established. As the first step, two researchers discussed and agreed on three major categories within juvenile Miranda waivers. Juvenile suspects are typically asked to affirm the following: (a) their own capacities (i.e., their ability to understand rights and ability to decide), (b) independent nature of the decision (i.e., their freedom from external influences—both positive and negative—and their opportunity to obtain advice), and (c) their awareness of consequences (i.e., risks of talking and effects of asserting rights). In reviewing the juvenile warnings, each researcher independently generated subcomponents for each category. Discussion and consensus were used to determine the final list of subcategories.

A similar process was utilized for parent/adult (i.e., an abbreviated term to encompass some combination of parents, guardians, custodians, relatives, or interested adults) waivers. The major categories included parent/adult’s (a) own capacities, (b) freedom from external influences, (c) decision about their child, and (d) capacity to decide for their child.

Thirty juvenile Miranda warnings were randomly selected. They were independently scored on the content of their warnings and waivers by two researchers. Interrater reliability was excellent; for content that occurred in at least three warnings, the average correlations are consistently high for the five Miranda components: .94 for Right to Silence, 1.00 for Risks of Talking, .99 for Right to an Attorney, .92 for Free Legal Services, and .80 for Continuing Rights.

Results

A total of 293 juvenile Miranda warnings were received from 238 counties in 38 different states. In addition, respondents from an additional 125 counties either sent general Miranda warnings or informed us that they did not utilize juvenile-specific warnings.¹ For the first juvenile survey (Rogers, Hazelwood, Sewell, et al., 2008), a total of 1,639 counties were contacted at least once to obtain 122 juvenile Miranda warnings. In the current survey, 3,068 counties were contacted, which yielded 249 of the 293 additional warnings that were not redundant (i.e., not identical wording from the same county) with the first and current surveys. Therefore, combined analysis utilized 371 juvenile Miranda warnings. Identical wordings in different Miranda versions occurred with only 12.4% of the warnings. Stated differently, 87.6% of the responding jurisdictions use uniquely worded warnings.

Lengths and Reading Levels

As a method of replicating earlier research on juvenile Miranda warnings, word lengths were compared across the first (i.e., Rogers, Hazelwood, Sewell, et al., 2008) and current surveys for both the Miranda warnings and waivers. Predictably, warnings for the original (M = 117.64, SD = 49.47) and replication (M = 113.92, SD = 49.12) surveys were similar in length, F(1, 368) = 0.47, p = .49, 95% CI [110.11, 102.17], d = 0.08. However, the Miranda waivers were slightly longer in the current (M = 67.24, SD = 38.68) than the first (M = 57.19, SD = 30.57) survey, although the effect size was modest, F(1, 329) = 5.31, p = .02, 95% CI [60.24, 68.17], d = 0.29. Nonetheless, averages can obscure important differences. As summarized in Table 1, we used Rogers, Hazelwood, Sewell, et al. (2008) 50-word categories to group the warnings. The most concerning issue was the substantial increase of Miranda material for the lengthiest category (i.e., > 225 words) presented. Overall, 40% of the warnings were grouped in this category, which averages in length 322 words (SD = 124.45 words). Moreover, lengthy advisements are the general norm with 64.9% of the presented Miranda material being 175 words or longer.

Table 1:

Length of Juvenile Miranda Material: Percentages for First, Current, and Combined Samples

	Percentages for Length Categories
Length^a	First	Current	d	Cumulative^a
225 or more	32.0	44.2	–0.35	40.1
175 to 224	28.7	22.9	0.18	64.9
125 to 174	23.0	20.5	0.11	86.2
76 to 124	13.9	10.4	0.15	97.8
75 or fewer	2.5	3.4	0.18	100.0

Note. Miranda material refers to total amount of information presented to suspects (i.e., warnings, waivers, and ancillary information). Because of rounding, the sum of percentages is not always 100%. Estimates of Cohen’s d were calculated for dichotomous proportions using the probit method.

The table follows Rogers (2008) in its use of 75 point categories.

This represents the combined percentages.

The Flesch-Kincaid reading levels were very similar for the first and current surveys on the Miranda components with an average Cohen’s d = 0.003 (range = −0.13 to 0.10). Similarly close results were also found for Miranda waivers (d = 0.03). For total Miranda warnings, the reading levels (first, M = 7.25, SD = 2.19; current, M = 7.93, SD = 1.70) increased significantly, F(1, 369) = 10.60, p = .001, 95% CI [7.50, 7.90]; however, this difference is less than one grade level and produced only a modest effect size (d = −0.35).²

The Flesch Reading Ease was used to categorize the combined surveys for the total Miranda material (i.e., warnings, waivers, and ancillary information presented to suspects; see Table 2). A disconcerting result was that 2.2% were written at a college graduate level, with a cumulative percentage of 5.2% requiring at least some college preparation. Over half (52.1%) of the juvenile Miranda material required at least an eighth-grade education, which is highly problematic for underachieving adolescents and likely insurmountable for preteen suspects. Moreover, the lack of very easy warnings (i.e., < fifth grade) is especially concerning in light of pervasive problems with impaired reading level among juvenile offenders (Texas Youth Commission, 2010; Vacca, 2008). Flesch-Kincaid grade estimates were also inspected because they provide greater precision than the Flesch Reading Ease. For the combined surveys, only 27 of the 371 (7.3%) juvenile warnings were consistently at or below a fifth-grade level.

Table 2:

Reading Ease of Miranda Warnings: Percentage at Each Level and Cumulative Percentage

Flesch Reading Ease Categories			Percentages of Miranda Warnings for Samples
Reading Level	Range of Scores	Grade Level	Percentage at Each Level	Cumulative Percentage
Very difficult	0-30	College graduate	2.2	2.2
Difficult	31-50	13th to 16th	3.0	5.2
Fairly difficult	51-60	10th to 12th	12.4	17.6
Standard	61-70	8th to 9th	34.5	52.1
Fairly easy	71-80	7th	38.5	90.6
Easy	81-90	6th	9.4	100.0
Very easy	91-100	5th	0.0	100.0

Note. Cumulative percentages provide a simple means to ascertain the percentages at or above each reading level.

Juvenile courts, the American Bar Association, and policy makers are likely to be concerned about the length and reading difficulty of juvenile Miranda warnings. Although documenting these vexing problems is valuable, the development of better alternatives is clearly needed. Therefore, we inspected the individual Miranda components for easily understood (i.e., Grade 6 or less) and concise (i.e., 15 words or less) examples. Because we found no quantitative methods to estimate listening comprehension, we relied on Flesch-Kincaid estimates for both oral and written advisements. Toward this objective, Table 3 provides multiple examples for each Miranda component.

Table 3:

Representative Examples of Concise and Easily Read Miranda Components

Component	Words	Grade	Example
Silence	8	0.8	You do not have to talk to anyone.
	7	2.3	You have the right to remain silent.
	4	3.7	You can remain silent.
Risk of talking	10	3.7	Anything you say can be used against you in court.
	8	3.8	Anything you say can be used against you.
Attorney	7	0.6	You have a right to a lawyer.
	9	1.0	You have the right to counsel at this time.
	9	3.7	You have the right to consult with an attorney.
Parent	11	2.7	You have the right to have one or both parents present.
	12	4.8	You have the right to have your parents with you during questioning.
Free legal services	12	3.8	If you cannot afford a lawyer, the Judge will get you one.^a
	11	5.9	If you cannot afford a lawyer, one will be provided free.
Continuing rights	8	3.8	You may stop this questioning at any time.
	13	3.1	If you do talk to the police, you can stop at any time.^a
	11	3.7	You have the right to leave this interview at any time.
Waiver of rights	14	0.6	Do you understand each of these rights? Do you wish to talk with me?
	15	3.1	Do you understand these rights? Are you willing to answer our questions at this time?
	12	4.8	Knowing these rights, are you willing to answer questions at this time?

To standardize the format, some pronouns were changed from I to you; reading levels did not change.

Juvenile Miranda Content

Some variations in juvenile Miranda content are expected across surveys (see Table 4); however, the current data generally replicate the first survey. Regarding Table 4, we will only highlight substantial differences (ds > |0.50|) and comment on total percentages. Regarding the Right to Silence, the majority of juvenile warnings across the combined surveys (60.4%) appear to assume that no explanation is necessary, and very few (12.1%) explain this right in the simplest terms (e.g., “not have to talk”). Although some shift (e.g., definition of a judge) was observed between the first and the current surveys, most warnings apparently assume that juveniles will grasp the overall context of criminal proceedings.

Some juvenile Miranda warnings stress that inculpatory information shared with law enforcement may eventuate in a transfer to adult court—a move that potentially leads to a dramatic escalation in the magnitude of criminal sanctions. Combining across surveys, 10.0% warn juvenile suspects of this possibility. Importantly, most versions state this heightened risk in clear terms (prosecuted or tried in adult court). In contrast, a very small percentage (1.2%) use ambiguous legalese (e.g., “certified” as an adult).

As described in the Introduction, juvenile offenders are viewed as having substantially greater needs for competent input. In addition to the Right to an Attorney, many warnings specify the option of conferring with a parent or guardian, with some local variations referencing access to other “interested” adults. Because nearly all juvenile suspects will lack independent financial means to retain counsel, the specification of free legal services appears essential; otherwise, youth in custody may assume that their parents or guardians will shoulder the cost of representation. A smaller percentage in the current as opposed to the first survey included this information, resulting in less than one third (30.5%) of the total warnings clarifying this matter.

For the fifth component, 16.4% of the combined warnings omit any mention of Continuing Rights. Of those including the fifth component (see Table 4, section 5a), a small percentage of the combined surveys (6.6%) utilizes legalese (e.g., “withdraw your waiver”); this small percentage is a positive finding because such legalese likely represents a major barrier to accurate understanding. Of great concern, about one fourth (26.2%) of the warnings mischaracterize the reassertion of Right to Silence as constrained (i.e., until counsel is available). Finally, Constitutional safeguards are infrequently explained. Although Miranda clearly specified that asserting the Right to Silence could not be used as evidence of guilt, most juvenile Miranda warnings (87.1%) do not mention this Constitutional protection. Regarding the consequences of asserting Miranda rights, most warnings (92.8%) are silent on the fact that exercising their rights would likely free juvenile suspects from further questioning.

Table 4:

Content Analysis of the First and Current Surveys of Juvenile Miranda Warnings: Major Variations for Each Miranda Component

		Percentages for Surveys
Miranda Component	Major Variations	First	Current	d	Total %^a
1. Right to silence	Unexplained	54.9	63.6	–0.22	60.4
	Not have to answer questions	11.5	10.7	0.04	11.0
	Not have to make a statement	15.6	25.2	–0.34	22.0
	Not have to talk	18.0	9.1	0.42	12.1
2a. Evidence against you	Unspecified context	8.2	20.0	–0.55	16.2
	Evidence in court, trial, etc.	91.8	80.0	0.55	84.7
2b. Explanation of court	Define a judge	3.3	0.4	0.81	1.4
	Define a court of law	1.6	0.4	0.51	0.8
	Sports analogy: like an umpire	1.6	0.4	0.51	0.8
2c. Adult court	Certified as adult	2.5	0.8	0.44	1.2
	Transfer to adult court	5.7	1.2	0.68	2.8
	Specify crimes that may get you transferred	0.8	0.0	—	0.3
	Prosecuted/tried in adult court	6.6	7.6	–0.08	7.5
	Any of the above	14.3	7.9	0.34	10.0
3a. Right to an attorney	Purpose is unexplained	3.3	6.5	–0.32	5.4
	Passive function only: “be present”	34.4	38.1	–0.10	36.8
	Active function: “advise” or “consult”	62.3	54.7	0.20	57.0
3b. Timing of attorney access	During questioning only	18.0	25.1	–0.24	22.7
	Before and during questioning	73.0	63.2	0.28	66.2
	At anytime	6.6	3.6	0.29	4.6
3c. Right to guardian	Parent	41.0	47.0	–0.15	45.1
	Guardian	32.0	37.3	–0.14	35.7
	Custodian	11.5	21.3	–0.40	18.1
	Relative	3.3	0.4	0.81	1.4
	Adult friend or other person	9.0	6.0	0.21	7.0
	Efforts to locate parent	4.9	3.2	0.20	3.8
	Parent presence required: “must have”	1.6	2.4	–0.16	2.2
4. Access to free legal services	Possible cost to client is not addressed	57.4	75.4	–0.50	69.5
	Free services are specified	42.6	24.6	0.50	30.5
5a. Reassertion of rights	Legalistic only (e.g., “withdraw your waiver” or “exercise rights”)	12.1	4.0	0.58	6.6
	Simple (e.g., “stop at anytime”)	87.9	96.0	–0.58	93.3
5b. Timing of reassertion	During questioning only	4.0	0.5	0.82	1.7
	Before and during questioning	1.0	2.0	–0.27	1.7
	At anytime	91.9	95.5	–0.30	94.4
5c. Limits on right to silence	Limited reassertion of silence: can remain silent until counsel is available	25.3	26.7	–0.04	26.2
	Not limited	74.7	73.3	0.04	73.8
5d. Reassertion of right to parent/guardian	Parent	4.0	1.6	0.39	2.7
	Guardian	2.0	1.6	0.09	2.0
	Custodian	0.0	0.8	—	0.7
	Relative	4.0	0.0	—	1.3
	Adult friend or other person	4.0	0.4	0.90	1.7
Constitutional protections	Unexplained	82.0	82.3	–0.01	82.2
	Assertion of rights cannot be used as evidence of guilt	4.1	10.8	–0.50	8.6
	Assertion of rights stops the interrogation	13.9	6.8	0.41	9.2

Note. Estimates of Cohen’s d were calculated for dichotomous proportions using the probit method. Effect size cannot be calculated when one proportion equals zero. Column percentages do not necessarily equal 100% because of (a) rounding and (b) some versions do not include that content (e.g., 2c. Adult court).

This represents combined percentages across surveys.

Juvenile and Parent/Adult Waivers

Formal Miranda waivers are included in 231 of the 249 (92.8%) juvenile advisements. Juvenile waivers are often lengthy passages averaging 67.24 words (SD = 38.68) that are provided after warnings and are typically the most proximal communication to the waiver decision. As such, they provide a critical context for rendering the far-reaching decision to relinquish or exercise Constitutional safeguards against self-incrimination.

Most juvenile waivers in the current study ask youthful suspects to affirm their general understanding of the Miranda rights (see Table 5). While this understanding is often written in plain English, a substantial minority (15.2%) use legalese, such as the “waiver of rights” or “Constitutional rights.” Interestingly, advantages of exercising rights, either then (e.g., the risks of talking, 1.8%) or subsequently (e.g., the ability to reassert rights, 7.8%), are rarely mentioned. In four instances (1.7%), juvenile suspects are cautioned that the reassertion of rights will not undo any past inculpatory admissions. It is unclear how youthful suspects might interpret the meaning of this statement; possibilities include (a) the futility of reasserting rights after any substantive admission or (b) the exercise of restraint because of the irrevocability of any admissions.

For the waiver decisions, about half of juvenile waivers evidenced considerable care in asking suspects to affirm freedom from external influences. For negative external influences, common affirmations in the current study include freedoms from threats (53.7%), pressure (27.7%), and coercion (20.3%). Interestingly, when positive external influences are included (53.7%), they mostly rely on a very general word, promises, and rarely clarify its context (e.g., promises of leniency or special treatment).

Most waivers (86.1%) explicitly ask juvenile suspects to waive their rights (see Table 5). Yet, very few ask these same juveniles whether they wish to exercise their rights, such as those to counsel (5.6%) or silence (0.9%). Questions about waiving rights often use positive words, such as willing (45.9%) or wish to (35.1%). Whether such positive terms influence juveniles’ decisions to waive their rights is an empirical question.

Table 5:

Content Analysis for Juvenile Waiver of Miranda Rights

Description of Content	Major Variations	n	% of Warnings
Miranda understanding
Comprehension (simple)	Understand my rights (stated generally)	168	72.7
	Right to silence	9	3.9
	Right to counsel	9	3.9
	Right to a parent, guardian, adult friend, etc.	10	4.3
Comprehension (legalese)	Understand the waiver of rights	22	9.5
	Advised of constitutional and statutory rights	8	3.5
	Understand my constitutional rights	9	3.9
	Any of the above	35	15.2
Risks of talking	Can be used against me	2	0.9
	Used to determine the disposition (legalese)	2	0.9
Opportunities/protections	Opportunity to discuss with parent, lawyer, etc. (no mention of private communication)	8	3.5
	Opportunity to talk privately with parent, lawyer, etc.	6	2.6
	Parent/guardian will be conferred with	2	0.9
	Parent, lawyer, etc. were present when advised of rights	8	3.5
Reassert rights	Any time prior to the final hearing, can change mind and request counsel	2	0.9
	Change my mind at any time and say I want my rights	8	3.5
	Stop answering at anytime	2	0.9
	Can exercise rights at anytime	2	0.9
Consequences of reasserting rights	Reassertion will not affect what I have already done or said	4	1.7
Miranda waivers and decisional abilities
Freedom from negative influences	Threats	124	53.7
	Pressure	64	27.7
	Coercion	47	20.3
	Persuasion	12	5.2
	Compulsion	11	4.8
	Without fear	8	3.5
	Forced	7	3.0
	Mental or physical force	1	0.4
	Duress	1	0.4
	Any of the above	125	54.1
Freedom from positive influences	Promises	124	53.7
	Special treatment	5	2.2
	Offers of deals	4	1.7
	Offers of leniency	1	0.4
	Bribes	1	0.4
	Any of the above	124	53.7
Decision: Waivers (simple language)	Willing to answer questions, talk, or make a statement	106	45.9
	Wish to make a statement, talk, or answer questions	81	35.1
	Do not want to talk with parent or guardian	12	5.2
	Do not want a lawyer	77	33.3
	Willing to answer questions without a parent etc.	11	4.8
	Consent to questioning or interview	1	0.4
	Any of the above	179	77.5
Decision: Waivers (legalese)	Waive my rights	47	20.3
	Sign a waiver	24	10.0
	I hereby waive these rights	15	6.5
	Waive my right to silence	8	3.5
	Wish to continue the proceedings	3	1.3
	Decided not to exercise these rights	2	0.9
	Any of the above	81	35.1
Decision: Exercising rights (simple language)	Want attorney/desire to speak to attorney	13	5.6
	Want parent or guardian	7	3.0
	Refuse to answer questions	2	0.9
	Any of the above	15	6.5
Capacity to decide	Freely and voluntarily (or willingly)	56	24.2
	Knowingly	17	7.4
	Intelligently	6	2.6
	Understand and know what I am doing	58	25.1

Parent/adult waivers (n = 37) are utilized in conjunction with juvenile waivers in only a small percentage (14.9%) of total waivers. Unexpectedly, these waivers focus on the parent/adult’s capacities and typically do not include their appraisals of juveniles in custody. Given the small number, Table 6 focuses on the key categories. Similar patterns are observed on parent/adult waivers, as the juvenile counterparts, regarding parent/adult’s comprehension of Miranda rights and their freedom—particularly from negative external influences. Regarding the waiver decision, all parent/adult waivers provide an opportunity for these adults to certify their approval of the juvenile’s waiver of rights, but only 5.4% allow them to document their disapproval. An important empirical question is whether the parent/adult’s decision to consent is determinative of the juvenile waiver of Miranda rights. In jurisdictions where the Miranda process is digitally recorded, it would be possible to examine how often the parent/adult’s consent overcomes a juvenile’s initial reluctance.

Table 6:

Content Analysis for Parent/Adult Waivers in Juvenile Miranda Warnings

Parent/Adult Waivers in Juvenile Cases	N	% of Parental Waivers
Comprehension
Understand rights (general)	26	70.3
Right to counsel	6	16.2
Right to presence of parent during questioning	1	2.7
Advised of rights	1	2.7
Any of the above	32	86.5
Freedom from external influences
Threats	13	35.1
Coercion of any kind	11	29.7
Pressure	11	29.7
Force	1	2.7
Any of the above	14	37.8
Promises	13	35.1
Parent’s decision
Agree/allow/permit child to talk/answer questions	19	51.4
Agree/allow/permit child to make statement	15	40.5
Consent to child’s waiver of rights	3	8.1
Consent to child giving up his/her right	4	10.8
Consent to child being interviewed/answering questions	4	10.8
Approve of the child’s decision to give up these rights	1	2.7
Do not want attorney for self (parent)	13	35.1
Do not want attorney for child	16	43.2
Any of the above	35	94.6
I approve/disapprove of child’s decision to waive rights	1	2.7
Refuse to consent	1	2.7
Parent’s capacity to decide
I understand what I am doing	13	35.1
Intelligently	5	13.5
Voluntarily	8	21.6
Any of the above	19	51.4

Discussion

Comprehension of Miranda Warnings

Rogers (2008) recommended the elimination of the worst-of-the-worst Miranda warnings as a first, presumably noncontroversial step toward improving procedural and substantive justice. In light of the current data, the worst-of-the-worst juvenile Miranda material either (a) is excessively long, containing at least 225 words (40.1%) or (b) requires some college education (5.2%). The lengthiest category exceeds 300 words (M = 321.99, SD = 124.45). This extreme length poses a formidable challenge to working memory that is acutely exacerbated by oral advisements. We used Miller’s (1956) magic number of 7±2 concepts as a benchmark for working memory. Because multiple words are usually involved in the expression of a concept, we applied Baddeley’s (1994) review of verbal chunking to estimate the number of words per concept in Miranda warnings. The upper range is 8.11 words per concept. When applied to the lengthiest category (322 words ÷ 8.11), a rough but conservative estimate is that a minimum of 40 concepts must be retained and processed. Such lengthy passages exceed by a multiple of four, the abilities of adults with excellent working memories (i.e., 40 Miranda-relevant concepts vs. Miller’s maximum of nine concepts). To provide a more recent reference point for orally presented material, the Wechsler Memory Scale–Fourth Edition (Wechsler, 2009) Logical Memory test assesses adults’ abilities to remember 25 comparatively simple concepts provided separately in two relatively brief passages (65 and 85 words). As well-educated adults (56.9% of the sample had at least some college education), they are considered to have superior memories if they can remember at least 72% of the concepts. Given their multiple advantages (maturity, education, and relatively short passages), even the adults with the best memories may be expected to miss a substantial number of key concepts in juvenile Miranda warnings.³

Excessively long juvenile Miranda warnings pose formidable challenges for written as well as oral advisements. The average reading level for lengthiest category is mid-eighth grade (i.e., M = 8.57) to achieve > 75% comprehension. Moreover, the sheer length of these warnings is likely to cause further decrements in reading comprehension. For purposes of comparison, oral reading comprehension on the Woodcock-Johnson Tests of Achievement (Woodcock, McGrew, & Mather, 2009), a well-established measure for this construct, utilizes passages of fewer than 100 words, which average only 38.40 words (SD = 27.83).

The elimination of juvenile warnings meeting either excessive length or some college criteria would mean that nearly half would be excluded as functionally unworkable. If simple, concise warnings were substituted, then hundreds of thousands of juvenile suspects would be affected. Although the Supreme Court of the United States has held steadfastly to a totality of the circumstances approach when judging the adequacy of juvenile Miranda waivers, this determination does not mean that a statutory or agency-driven approach to crafting more valid and reliable waiver procedures would run afoul of Constitutional review. Under these circumstances, such a review would never be invoked because state and local governments are always free to apply standards that exceed Constitutional minima for the preservation of individual rights, while simultaneously making law enforcement more efficient at safeguarding procedural justice for juvenile suspects. With these considerations in mind, it would clearly be possible to consider carefully delineated per se rules for eliminating functionally unworkable warnings.

Juvenile Miranda research with its strong emphasis on comparisons of quantified data may lose sight of its applicability to individual cases. As a concerning example, one case involves 12-year-old Paul Gingerich, who was Mirandized and subsequently confessed (Green, 2010). Putting aside substantial situational stressors (e.g., the all-night drive with police officers) and likely deficits (a police videotape of a “slouching, seemingly uninterested” child giving a “mumbled assent to waive his rights”; para. 8), the question remains whether this sixth grader adequately comprehended Miranda components and provided a knowing and intelligent waiver. Although his expected reading level falls far short of the typical juvenile warning, this child received an oral advisement. While addressing the issue of literacy, it provides little assurance of understanding. At least with adult defendants, oral advisements consistently produce poorer comprehension than written advisements for identical warnings at any reading level (Rogers, 2008). In the case of Paul Gingerich, the validity of the Miranda waiver was highly consequential in light of his murder charge and subsequent transfer to adult court.

Context and Miranda Waivers

Rogers (2008) underscored the paradox of asking suspects with potentially compromised abilities to affirm their competencies and then using these affirmations (e.g., I understand my rights) as proof of competency to waive Miranda rights. In this regard, juvenile waivers focus exclusively on children’s abilities without providing the option to express confusion or a lack of understanding. A similar pattern emerges regarding freedom from external influences. Juvenile suspects are asked to affirm that their abilities were free from threats, pressure, and coercion. Such affirmations are also paradoxical. If juvenile suspects are experiencing coercion to comply, then what value can be given to their coerced affirmations of no coercion?

Given issues of acquiescence and deference to authority typically ascribed to children and adolescents (e.g., Soto, John, Gosling, & Potter, 2008), an important issue is whether juvenile suspects are (a) given balanced alternatives or (b) subjected to one-sided questioning. Oskaloosa County in Iowa provides a good example of balanced alternatives for its written waiver, which is checked by the juvenile:

At this time, having these rights in mind:

__ I refuse to answer any questions.

__ I desire to speak with an attorney before answering any questions.

__ I am willing to give a statement, answer questions, and waive my right to have an attorney present.

Although the first choice could be reworded slightly to avoid any notion of disobedience (e.g., substitute choose not for refuse), it otherwise serves as an exemplar of an even-handed display of balanced alternatives.

In contrast to balanced alternatives, one-sided questions provide only a single choice for which a negative response could be construed as uncooperative. As noted previously, close to half (45.9%) of juvenile waivers contextualize the inquiry as a matter of “willingness,” whereas others use such terms as “wish” and “want.” As noted, it is an empirical question whether juvenile suspects in custody perceive such questions as true choices or implied expectations from police officers and others in authority.

Juvenile Miranda waivers are typically characterized as matters of personal choice rather than legal decision making. It would be interesting to see what differences would emerge if these questions were explicitly contextualized as a formal relinquishment of Miranda rights. An example would be, “Do you believe it is in your best legal interest to talk to us without the benefit of a lawyer’s advice?” Rather than responding with a personal preference, the legal context would accurately frame the juvenile’s decision.

Parent/Adult Waivers and Role

The most striking omission in the parent/adult waivers was the complete absence of any description regarding their official role. When the custodial suspect is a juvenile, the purpose of enabling the presence of a parent or interested adult is to ensure that children are not compelled to make a serious decision bereft of a parent’s support to which they have been accustomed—and on which they likely have relied—during their childhood. In this fashion, the juvenile justice system acknowledges that juveniles often lack the requisite maturity and capacity for judgment and need rely on parental advice and their decisional abilities (Parham v. J. R., 1979).

Parent/adult waivers generally provide similar information and questions as found in the juvenile waivers. Unexpectedly, the emphasis is on the adult’s understanding and decision making, rather than that of the juvenile being held in custody. Without being explicitly asked, it is unknown how many parents will carefully consider their children’s ability in consenting to the waiver of their Constitutional safeguards. One subcomponent of parent/adult waivers raises an important concern when they ask whether the parent or interested adult wants an attorney for themselves. Although this inquiry could be construed as a simple formality, it might also be interpreted as warning that this parent or interested adult could also be in legal jeopardy.

Nearly all (96.8%) of the warnings in the current study specify a juvenile’s right to have a parent or guardian present. However, research indicates that a parent’s presence may not function as the protective safeguard. For example, in a sample of juvenile defendants, none of the youth reported their parents advised they remain silent during the police interrogation (Viljoen, Klaver, & Roesch, 2005). In fact, many parents may direct the child to talk to the police (Viljoen et al., 2005) or may not offer any assistance at all to their child (Grisso, 1981). Moreover, the paucity of help from parents may be, in part, due to their own deficits in Miranda comprehension. Although parents demonstrate greater understanding about Miranda components, this improvement does not necessarily extend to other aspects of Miranda knowledge (Woolard et al., 2008). For instance, parents exhibit similar deficits in knowledge as detained youth regarding police strategy (i.e., whether police can lie during interrogation). Interestingly though, youth (51.2%) significantly outperformed parents (35.3%) when asked whether police must wait for parents before interrogation (Woolard et al., 2008).

Policy Implications

Criminal justice policy is—and will always remain—an exercise in brinksmanship. The fragility of the balance between maintaining order and honoring the rights of the individual pervades our centuries-old Constitution and is borne home with each legal development. Champions of the prosecution and the defense bar alike are acutely aware that for either side to “win” too decisively in the policy arena would ultimately mean the unraveling of our entire system of criminal jurisprudence. For maintaining order, should law enforcement personnel be given free rein to extract information from a custodial suspect by any linguistic subterfuge or psychological means at their disposal? For honoring individual rights, should guilty defendants be exempted from all accountability because police officers did not do their utmost at the time of arrest to prevent a valid admission of wrongdoing? These spectrum-defining questions have been answered—in the negative—to the satisfaction of every rational constituency. For procedural justice, it is the balancing of societal needs and individual rights.

The Supreme Court of the United States has consistently shown a heightened appreciation for the lack of maturity and diminished capacities of juvenile offenders. In Roper v. Simmons (2005), despite the horrific details of the crime in question, the Court recently was nonetheless compelled to affirm its earlier stance in Johnson v. Texas (1993, p. 367) that a child’s “lack of maturity” and “underdeveloped sense of responsibility” will “often result in impetuous and ill-considered actions and decisions.” The Court cited similar reasons in Graham v. Florida (2010) for its conclusion that “for a juvenile offender who did not commit homicide the Eighth Amendment forbids the sentence of life without parole” (p. 2030). This perspective on the status of children who find themselves within the realm of the criminal justice system can be traced back for several decades. In Haley v. Ohio (1948), the Court acknowledged that an adolescent “cannot be judged by the more exacting standards of maturity” applicable to adults (p. 599). It commented in Kent v. U.S. (1966) on the bases for “society’s special concern for children” in their role as a person accused of a crime (p. 554). Moreover, the Court in In re Gault (1967) expressed its disquietude regarding cases in which it appeared that “the confessions were products of the will of the police, instead of the boys” (p. 52).

Concluding Thoughts

Improvements in juvenile Miranda warnings and waivers, as discussed in the Introduction, can be framed in terms of comprehensiveness (Hynes, 2010) and conciseness (Rogers, Hazelwood, Sewell, et al., 2008). As documented by past studies and the current research, juvenile Miranda warnings have clearly opted for the former, sometimes with utter disregard for the length of the material (e.g., greater than 300 words) or its abstruse language (e.g., requiring more than a high school education). However, we are concerned whether conciseness alone is sufficient for a full understanding of Miranda rights and their critical implications to juveniles’ cases. An unexplored option would be to ask juveniles to express their goals in simply stated alternatives. Here is a straightforward example: “As a juvenile in custody, do you want to (a) protect your legal rights (__yes, __no), (b) shorten the time of police questioning, (__yes, __no), and (c) reduce the chances of being convicted (__yes, __no). Any affirmative response could be construed as an implicit invoking of Miranda rights. In Berghuis v. Thompkins (2010), the Supreme Court affirmed the Miranda decisions do not have to be formally asked and recorded, at least with implicit waivers of Miranda rights. If the juveniles’ expressed goals are potentially thwarted by impaired reasoning, could a goal-based procedure be utilized with juveniles for implicit exercising of Miranda rights?

The stage is set for systematic investigations of comprehensive and concise juvenile Miranda warnings and the effectiveness of parent/adult waivers in ensuring procedural and substantive justice. Building on the foundation set by Grisso (1981) and Goldstein et al. (in press), research is urgently needed on how to convey Miranda rights in a simple comprehensible manner that stresses both the meaning of the Miranda rights and the magnitude of the decision. While challenging, this task is achievable. Putting aside legal debates, Miranda researchers should heed Coyote v. United States (1967):

Surely Miranda is not a ritual of words to be recited by rote according to didactic niceties. What Miranda does require is meaningful advice to the unlettered and unlearned in language which he can comprehend and on which he can knowingly act. We will not indulge semantic debates between counsel over the particular words used to inform an individual of his rights. The crucial test is whether the words in the context used, considering the age, background and intelligence of the individual being interrogated, impart a clear, understandable warning of all of his rights. (p. 308)

Footnotes

Authors Rogers, Drogin and Fiduccia are working on the Standardized Assessment of Miranda Abilities that is under contract and will be eventually published for use with adult populations. It does not pose a conflict of interest to the current study involving juvenile Miranda warnings. This study was supported by grants (0615934 and 0817689) from Law and Social Sciences Program, National Science Foundation to Richard Rogers as the principal investigator. Any opinions, findings, and conclusions, or recommendations expressed in this material are those of the authors and do not necessarily reflect the views of the National Science Foundation.

Notes

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