The California Supreme Court reversed a decision of the court of appeal. The court held that continued interrogation following a juvenile’s postwaiver request to speak with his mother did not violate Miranda v. Arizona (1966) 384 U.S. 436 unless a reasonable officer would have understood the request to be an unambiguous and unequivocal request for legal counsel.

Fifteen-year-old Samuel Nelson was brought to a police station for questioning in connection with five burglaries and a murder. Nelson waived his Miranda rights. During the ensuing interrogation, he admitted burglarizing the home where the elderly murder victim was found, but denied any involvement in her murder.