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The procedural protections of the Bill of Rights apply to juveniles,' but not in precisely the same way as they apply to adults. One way juvenile protections differ is in the factors courts consider in determining the validity of a juvenile's waiver of the privilege against self-incrimination or of the right to counsel. The presence of an "interested adult,"2 which usually is irrelevant to the validity of an adult's waiver,3 is an important factor in a court's determination of whether a juvenile's waiver is knowing, voluntary, and intelligent, and thus valid.' The United States Constitution requires that courts consider the presence of an interested adult as part of an evaluation of the totality of the circumstances surrounding a juvenile's waiver. Some states go fur-

"Interested Adults" with Conflicts of Interest at Juvenile Interrogations: Applying the Close Relationship Standard of Emotional Distress