In re C.S.

C.S. (defendant) was an almost 14-year-old who participated in a multi-day series of crimes. After his arrest, C.S. waived his right to an attorney and admitted his crimes to police. Before his initial hearing, C.S. and his mother received a notice explaining C.S.’s right to an attorney, which stated he had the right to be represented by counsel throughout the proceeding and that if he could not afford an attorney, one would be provided for him. The next page contained a waiver that provided the option of waiving C.S.’s right to counsel. C.S. and his mother both signed the waiver. A lengthy colloquy was held during C.S.’s hearing before a magistrate judge, where the judge reiterated C.S.’s right to an attorney and C.S. again waived that right. The judge explained the charges, and C.S. indicated that he understood and admitted each one. C.S.’s mother stated that she had not yet read the police report and she and C.S. had not spoken since his arrest. The judge informed C.S. that additional felony charges would likely follow. The judge then found C.S. delinquent of the charges that had already been filed and sentenced him to 12 months in a juvenile-detention facility. The judge determined that C.S. would not be housed in the same facility as his brother because it appeared from the record that C.S. was trying to be committed to custody so he could be with his brother, who was already in a juvenile-detention facility. C.S. and his mother waived any objections to this decision and consented, and the trial court accepted the decision. C.S. appealed, arguing in part that his rights to counsel and due process were violated. The court of appeals rejected that claim. C.S. appealed again.