The following excerpt is from U.S. v. Glover, 596 F.2d 857 (9th Cir. 1979):
We believe that United States v. Young, 355 F.Supp. 103 (E.D.Pa.1973), is more persuasive here. In Young, the defendant was convicted of bank robbery, partly on the basis of a confession obtained after federal agents read him his rights and he signed a waiver form. Tests revealed that he had an intelligence level slightly lower than Glover's and had a second grade reading ability. The defense expert testified that he could not understand his constitutional rights sufficiently to waive them, even if they were read to him. The government expert testified to the contrary. He had been arrested numerous times in the preceding three years. On the basis of these facts, the court concluded that
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