The In re Gault, 387 U.S. 1 (1967) decision held that juvenile offenders are constitutionally entitled to assistance of counsel in delinquency proceedings. In the two decades since Gault, however, its promise remains unrealized. Although studies show that juveniles charged with the equivalent of felonies are more likely to have attorneys, these charges constitute only a small fraction of juvenile courts' dockets. Substantially higher proportions of juveniles charged with minor property offenses or probation violations are unrepresented. The most commonly offered explanation of nonrepresentation is that juveniles waive their right to counsel. Even when juveniles are represented by counsel, various factors may result in the representation being less than vigorous. These can include organizational pressures on attorneys to cooperate or an internalization of a court's treatment philosophy. In cases where prior convictions affect juvenile adjudication, automatic and mandatory appointment of counsel is the obvious device to assure the validity of prior convictions. 19 notes