In re C.S.

{¶ 1} Forty years after the Supreme Court’s watershed ruling in In re Gault (1967), 387 U.S. 1, 87 S.Ct. 1428, 18 L.Ed.2d 527, we address important questions concerning the scope of a juvenile’s right to counsel in a delinquency proceeding and the waiver of that right. We hold that the juvenile’s right to counsel is a right that he may waive, subject to certain conditions.

Relevant Background

{¶ 2} Appellant, C.S., was brought before the Juvenile Division of the Licking County Court of Common Pleas on August 9, 2005. At that time, he was almost 14 years old.

A. The Incidents

{¶ 3} C.S.’s…