In the case of State v. Westmorland No. 2-05-1093 Dec. 14, 2006 the Illinois Appellate Court, Second District, upheld the trial court's decision to suppress a 17 year old defendant's condition, focusing on the officers failure to afford the defendant any "concerned adult" protections. Here is an excerpt from their decision:

"The aspect of the interrogation that we find most significant is the total failure by the police to afford defendant any of the "concerned adult" protections explained above. The detectives made no attempt to locate defendant's parents before or during the interview nor did they afford him the assistance of a juvenile officer. They also refused defendant's two requests during the interview to speak with his mother.

Here, the police refused defendant's two requests to contact his mother and made no effort themselves to contact defendant's parents before or during the interview. As in Knox, there was no juvenile officer present during the interview to offset the absence of a parent. We recognize that defendant was given Miranda warnings and did not receive any promises or threats. The same, however, was true of the respondent in V.L.T. and the defendant in Knox, but in neither case did this fact override the coercion that the court found in the remaining circumstances. Likewise, the provision of Miranda warnings and the absence of promises or overt threats did not ameliorate the pressure brought to bear on defendant, a 17-year-old who was "immature" for his age and became "terrified" while in custody when his two specific requests to contact a parent were refused and when Galason raised his voice to him and said, "I don't give a shit if you go to jail or not." If section 5-405(2) of the Act and the parallel common-law protections are to have real force, we cannot countenance the police action in this case but must find that defendant's confession was involuntary."