California, United States of America
The following excerpt is from Garth D., In re, 127 Cal.Rptr. 881, 55 Cal.App.3d 986 (Cal. App. 1976):
While no single one of the foregoing circumstances in isolation may have rendered the admissions to the probation officer involuntary, their cumulative effect compels the conclusion that the statements were the direct product of the coercive and illegal conduct of the police, probation officers and counselors. The fact that appellant is a minor demands emphasis. A 16-year-old boy cannot be judged by the exacting standards of maturity. Special care must be used in scrutinizing the record when a minor is involved. (Haley v. State of Ohio, supra, 332 U.S. at p. 599, 68 S.Ct. 302.) While there is no evidence that the physical abuse inflicted by the juvenile hall counselors constituted a calculated attempt to elicit statements from appellant, the striking and stripping incident may not be disregarded, particularly when he was told that things would be 'nicer' if he cooperated. It would require little imagination for a 16-year-old to conclude that the penalty
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