In re L.A.B.

{¶ 1} In this case, we are asked to determine whether Juv.R. 29 applies to probation revocation hearings in juvenile courts. We hold that it does. We also hold that the totality-of-the-circumstances test established in In re C.S., 115 Ohio St.3d 267, 2007-Ohio-4919, 874 N.E.2d 1177, ¶ 108, applies to determine whether a valid waiver of counsel has been made by a juvenile.

*113I. Case Background

{¶ 2} In August 2005, appellant L.A.B., then 13, was found delinquent by the Juvenile Division of the Summit County Court of Common Pleas for entering an enclosed porch and stealing a minibike. He was placed…