context: Eight other states statutorily require police to notify a minor's guardian or custodian immediately if a minor is taken into custody.
citation_a.signal: see
citation_a.parenthetical: holding that juvenile's request for parent is invocation of Fifth Amendment rights
citation_a.sentence: See People v. Gardner, 257 A.D.2d 675, 683 N.Y.S.2d 351 (1999) (observing that police are statutorily required to notify immediately guardian or parent of juvenile upon her arrest or statements made are inadmissible); Barrow v. State, 749 A.2d 1230 (Del.2000) (suppressing statements by juvenile -because parental notification statute violated); Palmer v. State, 626 A.2d 1358 (Del.1993) (reversing seventeen-year-old juvenile’s conviction because of police’s failure to timely notify custodian violated mandate of statute and constituted deprivation of defendant’s right to due process and self-incrimination rights); In re D.B., 303 Ill.App.3d 412, 237 Ill.Dec. 3, 708 N.E.2d 806, 811 (1999) (noting that purpose of law requiring immediate notification of parents when juvenile taken into custody “is to permit, where possible, a parent to confer with and counsel the juvenile before interrogation and confession”); Brown, supra, 182 Ill.App.3d 1046, 131 Ill.Dec. 534, 538 N.E.2d 909 (holding that police’s “flagrant[ ] violation]” of statute requiring officers to make reasonable attempts to notify parents among factors causing court to determine that defendant’s statement was involuntary and therefore should be suppressed); A Minor Boy v. State, 89 Nev. 564, 517 P.2d 183 (1973) (holding that consequence of deliberate violation of parental notification statute is suppression of statements made by defendant); State v. Johnson, 221 Mont. 503, 719 P.2d 1248 (1986) (holding that juvenile’s request for parent is invocation of Fifth Amendment rights); Sublette, supra, 365 No.2d 775 (observing that police officers’ failure to comply with statute requiring that parents be immediately notified upon arrest of child renders any statements made by juvenile inadmissible); M.M. v. State, 827 P.2d 1117 (Wyo.1992) (noting that law enforcement officials must comply with parental notification statute for juveniles’ statements to be admissible); MAC. v. Harrison County Family Court, supra, 566 No.2d 472 (finding that police’s blatant violation of juvenile’s statutory right to have parent present during interrogation required exclusion of any statements made).
citation_b.signal: cf.
citation_b.parenthetical: finding that mandates of notification statute were satisfied where "all reasonable efforts" were made by police to contact defendant's mother and not more than one hour could have elapsed before she was contacted and there was "no evidence of any intentional delay in contacting" defendant's mother
citation_b.sentence: Cf. A Minor Boy v. State, 91 Nev. 456, 537 P.2d 477 (1975) (finding that mandates of notification statute were satisfied where “all reasonable efforts” were made by police to contact defendant’s mother and not more than one hour could have elapsed before she was contacted and there was “no evidence of any intentional delay in contacting” defendant’s mother); In re Williams, 265 S.C. 295, 217 S.E.2d 719 (1975) (holding that statements are admissible in absence of showing that parents were not notified in accordance with statute).