What is the current standard for a minor to make a voluntary confession of a crime?

In People v. Lara (1967) 67 Cal.2d 365, 383, 62 Cal.Rptr. 586, 432 P.2d 202, a general rule for the guidance of courts in this area was established as follows: "... a minor has the capacity to make a voluntary confession, even of capital offenses, without the presence or consent of counsel or other responsible adult, and the admissibility of such a confession depends not on his age alone but on a combination of that factor with such other circumstances as his intelligence, education, experience, and ability to comprehend the meaning and effect of his statement."

The appellant is requesting this court to reject the "totality of circumstances" test and adopt a rule requiring the presence of a parent, attorney, or other interested adult before a minor can waive constitutional rights. We decline to do so. We believe the current standard is a flexible one and all salient considerations can be properly evaluated under the existing rule. A presumption that all minors are incapable of a knowing, intelligent waiver of constitutional rights is a form of stereotyping[134 Cal.App.3d 772] that does not comport with the realities of every day living in our urban society. Many minors are far more sophisticated and knowledgeable in these areas than their parents. Obviously, some are not. The guidelines set forth in Lara, properly applied, can benefit the total community more than the slot machine approach advocated by the appellant. (See Fare v. Michael C., (1979) 442 U.S. 707, 724-726, 99 S.Ct. 2560, 2571-72, 61 L.Ed.2d 197.)