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Name: U.S. v. John Doe
Case #: 99-50250
Court: US Court of Appeals
District 9 Cir
Opinion Date: 07/20/2000
Subsequent History: None

Juvenile appellant “John Doe” was arrested for transportation of marijuana. He was not advised of his rights for over three hours; his parents were not advised of his rights; and he was not brought before a magistrate for a day and a half. The failure to comply with the parental notification provision of 18 U.S.C. section 5033 resulted in prejudice because the minor lost the opportunity for parental advice about his rights prior to an interrogation which resulted in a confession. However, the statutory violations did not rise to the level of constitutional deprivation. The minor’s waiver of his rights was voluntary, and the delay did not constitute a violation of due process. There is no constitutional requirement that a parent be present for a juvenile’s confession to be valid.