The case of In re Gault (1967) extended Miranda rights to juveniles. However, recent studies show that approximately 90% of juveniles waive their Miranda rights during custodial interrogations, despite serious concerns that many are not capable of knowingly waiving those rights. The Supreme Court declined to review the case of H. v. California in 2016, which involved the question of whether a 10 year-old murder suspect could voluntarily, knowingly, and intelligently waive his Miranda rights during custodial interrogation.