People v. Polk 

Defendant was convicted, after jury trial, of first degree murder of one victim, and of attempted first degree murder of another victim. Police officer testified that he read Defendant his Miranda rights, and learned that Defendant was 17 years old. Defendant's answers to officer's questions, implicating himself in the shooting, were a "course of conduct indicating waiver" of his right to remain silent. Defendant exhibited a clear understanding of his right to counsel, and did not make an unequivocal, unambiguous request for counsel at any time. Videotape statement shows no outward indications that Defendant had a disability, and thus does not support his claim that his confession was involuntary, even though Defendant has a very low IQ and reading level. (MURPHY, concurring; NEVILLE, dissenting.)