How have the courts interpreted the waiver of the Miranda rights?

Doe next argues that the violation prevented Doe's waiver of his Miranda rights from being voluntary, knowing and intelligent. We review for clear error the district court's finding of knowing and intelligent waiver and review its conclusion of voluntariness de novo. See Doe III, 155 F.3d at 1074. The validity of Doe's waiver depends on the "totality of the circumstances," and the "lack of parental notification is one factor to consider...." Id. at 1073. Doe's age, background, experience and conduct are other factors relevant in applying the totality of the circumstances test. See United States v. Bernard S., 795 F.2d 749, 751 (9th Cir.1986). In considering these factors, the district court found that there was "nothing done that would indicate any kind of coercion, threats, promises or anything that would render the statement involuntary." The district court further found that Doe "was aware of his rights" and "knowingly and intelligently waived his rights and voluntarily made a statement for the specific intent of exculpating" his companions.