Does the interrogation of a minor in a juvenile dependency proceeding violate the Sixth Amendment?

Nor does People v. Chutan answer the question presented here. (People v. Chutan (1999) 72 Cal.App.4th 1276, 1283.) In Chutan, the court held that because the right to counsel applies only when a person stands accused in a criminal prosecution, and because a juvenile dependency proceeding is not a criminal prosecution, the defendant's interrogation did not violate the Sixth Amendment notwithstanding his representation by counsel in a related dependency proceeding concerned with placement of his children.¹⁰ (Ibid.) Moreover, the court noted that "the right to

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