In 1983, nearly half of the juveniles facing delinquency charges in Minnesota counties waived their right to be represented by counsel in juvenile court hearings. In addition, almost one half of the juveniles adjudicated delinquent for the felony of burglary waived their right to counsel before adjudication. Minnesota Juvenile Court Rules and Statutes provide for counsel at public expense for juveniles charged with crimes. While adults in Minnesota who are charged with gross misdemeanors or felonies cannot waive their right to counsel, juveniles are not protected by a similar check to their waiver of representation by counsel. Discussion focuses on code law establishing a juvenile's right to counsel, with special attention directed to the rights of juveniles under Minnesota statutes and procedures. It reports that a recent Minnesota study questions why such a surprising number of juveniles charged with delinquency in Minnesota juvenile courts waived their right to counsel. A question arises about the competency of juveniles waiving their right to counsel: did they understand the function of counsel and their decision to waive counsel? Two studies are cited of the competence of juveniles to understand and waive their right to counsel. The author argues that the totality of the circumstances test used in Minnesota does not guarantee that juveniles validly waive their right to representation by counsel. Therefore, an alternative test must be adopted and enacted by the Minnesota Legislature. 175 footnotes.