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Osterberg knew prior to starting the interview that Boyd was going to be charged whether he talked to him or not since the victim had already identified Boyd as the person who brandished the shotgun during the robbery. And although this method of interrogation may be permissible, particularly when interviewing an adult, we believe these methods may be ill-advised when interviewing a juvenile, in light of the additional scrutiny to which these procedures must be subjected. [fn] This is particularly true where, as here, the juvenile was interrogated without the aid of an attorney or a parent, and without being advised of the very serious charges he could be facing.” Blackwell dissents. In re: C.H., 306 Ga.App. 834, 703 S.E.2d 407 (November 17, 2010). Delinquency ruling upheld; juvenile’s statement properly admitted. “The record here reveals that C.H. was 14 years old when he gave his statement to police. Our courts have approved statements obtained from juveniles of this age. See Marshall v. State, 248 Ga. 227, 229(3) (282 S.E.2d 301) (1981). The record also reveals that C.H. had an eighth grade education and could read and write; he was informed of his constitutional rights under Miranda and signed a waiver form; he told the officer that he understood his rights; the officer told C.H. that he wanted ‘to talk to him about some damage that had been done’ at the home; C.H.'s mother was present during the questioning; C.H. was questioned prior to the filing of charges against him; the officer did not ‘yell or scream’ at C.H. during questioning; the questioning lasted less than one hour; and there is no indication that C.H. refused to give statement on a prior occasion or that he repudiated any statement he made during questioning. Under these circumstances, we cannot say that the trial court erred in allowing the admission of C. H.'s statement. See [ State v. McBride, 261 Ga. 60, 63-64(2)(b) (401 S.E.2d 484) (1991)]; In re: B.Y., 257 Ga.App. 253, 256-257(3) (570 S.E.2d 689) (2002); see also McKoon v. State, 266 Ga. 149, 150-151(2) (465 S.E.2d 272) (1996) (where juvenile not formally charged when he gave statement).” Dickerson v. State, 292 Ga.App. 775, 666 S.E.2d 43 (June 25, 2008). 1. “Although the juvenile code requires a person taking a child into custody to promptly give notice to a parent, guardian, or other custodian, OCGA § 15-11-47(c), there is no provision requiring a parent to be present during questioning. Marshall v. State, 248 Ga. 227, 228(2) (282 S.E.2d 301) (1981). It has thus been ‘consistently held that the custodial statement of a juvenile is not rendered inadmissible merely because it was made in the absence of a parent.’ Murray v. State, 276 Ga. 396, 398(3) (578 S.E.2d 853) (2003) (citations omitted). nstead, whether the juvenile is held incommunicado or allowed to consult with a parent is a factor in determining whether the statement was voluntarily and knowingly given. Id. at 397(2).” 2. Physical precedent only. Trial court properly admitted recording of sixteen-year old defendant’s conversation with his mother, made without their knowledge in interview room of jail after his arrest for armed robbery. Based on Lanza v. New York, 370 U.S. 139, 82 S.Ct. 1218, 8 L.Ed.2d 384 (1962) (no reasonable expectation of privacy in jails, including visitor rooms) and Katz v. United States , 389 U.S. 347, 88 S.Ct. 507, 19 L.Ed.2d 576 (1967) (rejects Lanza “protected areas” analysis, focuses on expectations of privacy that society is prepared to recognize as “reasonable.”). “Even though Katz thus called into question the continued viability of Lanza, post- Katz decisions have consistently followed Lanza and held that federal law permits the admission in evidence of monitored conversations in places such as jails, police cars, and police stations. [Cits.]” Also based on Meyer v. State , 150 Ga.App. 613 (258 S.E.2d 217) (1979) (no reasonable expectation of privacy on public phone at jail “with police personnel within her immediate vicinity”) and Burgeson v. State , 267 Ga. 102 (475 S.E.2d 580) (1996) (no reasonable expectation of privacy where “a hidden tape recording device captured a conversation between arrestees placed in the back of a patrol car”). Questionable here whether defendant had any objectively reasonable expectation of privacy, but tape shows that defendant and mother exhibited no subjective expectation, either, carrying on conversation without lowering voices even when police came in room, and making no request for privacy. Barnes concurs in judgment only on this point, would hold that a minor has a right to confidential consultation with a parent, on a par with attorney-client privilege. “Although I recognize that the majority has correctly analyzed the general precedents involving jail house interrogations, conversations on public telephones, and the like, I do not find these precedents controlling in this case because the parent’s involvement is mandated by OCGA § 15-11-47(c). Indeed, one of the criteria which must be considered before a juvenile's statement is admissible in this State is ‘whether the accused is held incommunicado or allowed to consult with relatives, friends or an attorney.’ Marshall v. State, 248 Ga. 227, 230(3) (282 S.E.2d 301) (1981); Riley v. State, 237 Ga. 124, 128 (226 S.E.2d 922) (1976). Consultation with a parent is meaningless if the police may surreptitiously record the conversation between the parent and child and the prosecutor may then play the recording to the jury. Therefore, just as we would not countenance the recording of a conversation between a defendant and his attorney, we should not permit the recording of a conversation between a juvenile defendant and his parent in this context.” In re: T.A.G., 292 Ga.App. 48, 663 S.E.2d 392 (June 18, 2008). Trial court properly suppressed juvenile’s statement to school administrator, finding that assistant principal was acting as agent for police, and that police officer/school resource officer was not merely present, but a participant, even though the principal asked the questions. 1. School official as

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