In re E. T. C
In In re E. T. C., 141 Vt. 375, 449 A.2d 937 (1982) the Court held that, for a waiver of a juvenile's rights against self-incrimination and to counsel under Chapter I, Article 10 of the Vermont Constitution to be voluntary and intelligent, the following criteria must be met:
(1) he must be given the opportunity to consult with an adult;
(2) that adult must be one who is not only genuinely interested in the welfare of the juvenile but completely independent from and disassociated with the prosecution, e.g., a parent, legal guardian, or attorney representing the juvenile;
(3) the independent interested adult must be informed and be aware of the rights guaranteed to the juvenile. Id. at 379, 449 A.2d at 940.