State v. Pablo, 100 N.E.3d 1068

At age 16, David Pablo (a ninth-grade student, Spanish-primary speaker, limited school performance) was removed from school by police, taken to the sheriff’s office, and interrogated for ~26 minutes without a parent or other adult present.
Police read a Miranda form aloud, pausing after each right; Pablo nodded and signed the waiver but testified he did not read it and signed because he felt he had to. No call to parents or offer to contact them was made.
Pablo had no prior experience with police or prior custody; his mother testified she was not notified and learned of his arrest later via media.
Trial court found, under the totality of circumstances, Pablo’s waiver was not knowing and voluntary and suppressed his statements/confession.
The State appealed, arguing the waiver was valid; the appellate court affirmed suppression, focusing on Pablo’s age, education, primary language, lack of adult involvement, and his stated belief that signing was mandatory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Pablo knowingly and voluntarily waived Miranda rights	Waiver valid: rights were read verbatim, Pablo nodded and signed	Waiver invalid: Pablo was a minor, limited education, Spanish-primary, inexperienced with police, and lacked parental/adult assistance	Waiver invalid under totality of circumstances; statement suppressed

Miranda v. Arizona, 384 U.S. 436 (warning and waiver requirements for custodial interrogation)
Johnson v. Zerbst, 304 U.S. 458 (waiver of rights must be knowing and intelligent based on totality of circumstances)
Fare v. Michael C., 442 U.S. 707 (juvenile’s age, experience, education, background, and intelligence are relevant to waiver analysis)
In re Gault, 387 U.S. 1 (juveniles are entitled to Miranda warnings and due process protections)
State v. Barker, 149 Ohio St.3d 1 (Ohio precedent requiring consideration of juvenile characteristics and parental access in waiver analysis)