CASE LAW REVIEW
People v. Murdock 979 N.E. 2d 74 (ILL.2012)
This factor considers whether the juvenile delinquent had an opportunity to consult with an adult interested in his welfare, either before or during the interrogation. The courts, in weighing in this factor, consider whether the police officer prevented the juvenile delinquent from conferring with a concerned adult, and if the police officer frustrated the concerned adults attempt to confer alone with the juvenile delinquent.
The court examines the concerned adult factor, as it is just one of many factors that will be examined in determining whether a juveniles confession was voluntary.
People v. Griffin 763 N.E. 2d 880 (ILL App 1 Dist. 2002)
There is no per se rule that juvenile delinquents must be allowed to consult with their parent prior to the police questioning the minor, but the courts have repeatedly held that a police officers’ conduct which frustrates parents’ attempts to confer alone with their child is particularly relevant and is a significant factor in the totality of the circumstances.
In re: A.R. 693 N.E. 2d 869 (ILL App 1 Dist 1998)
The police must make every reasonable effort to have a parent, youth officer, or other interested adult present before the questioning of the juvenile delinquent begins.
