Such diversity may be explained, at least in part, by the vagueness of standards and the failure of the Supreme Court to address open constitutional questions in this area of juvenile law. Some States hold the validity of a juvenile's waiver to a high standard, erecting safeguards such as "interested adult" statutes, disclosure requirements, or careful scrutiny of interrogation procedures. Other States afford juveniles little more protection than adults receive. Although the Supreme Court has yet to determine whether Miranda requirements fully apply to a juvenile's waiver of the privilege against self- incrimination in a juvenile versus criminal proceeding, most recent decisions begin their analysis of the admissibility of a juvenile's statements by considering Miranda rules. Certain States limit a minor's ability to waive the privilege against self-incrimination by requiring that an adult who has an interest in the juvenile's well-being be notified of and sometimes involved in the minor's custodial interrogation. In Fare v. Michael C, the Supreme Court adopted a "totality of circumstances" approach to determining the validity of a juvenile's waiver of the privilege against self-incrimination by identifying specific factors to be evaluated: age, experience, education, background, intelligence, and capacity to understand the consequences of waiver. With respect to a juvenile's waiver of the right to counsel, some States require that detailed disclosures of the consequences of a waiver be made to the juvenile. In some cases, these disclosures must be made on the court record at the time a juvenile seeks to waive the right. Another approach used to protect a minor's right to counsel is to limit the capacity to waive the right. 92 footnotes