In State v. Lohnes, the court held that prior to admitting a juvenile confession obtained while in custody, the State has the burden of showing a knowing, intelligent, and voluntary waiver of the right to counsel and a realization that any statements would be used in a subsequent adult trial. The court held in J.T. v. O'Rourke that limiting the necessity of juvenile court preliminary hearings to "serious offenses" is consistent with the juvenile system's goal of providing a nonadversarial atmosphere of care and guidance. Prior to the passage by initiative of an amended death penalty law, California's Supreme Court in People v. Davis held that minors were not subject to the penalty of death or life imprisonment without possibility of parole. 22 footnotes