In re Christopher K.

Juvenile Law Center filed an amicus brief in a case arguing two points: (1) that the state’s blended sentencing scheme allowing a court to impose a juvenile and an adult sentence, and then suspend the adult sentence unless the juvenile “violated the provisions of the juvenile sentence” violated due process because it was overly vague; and (2) that a youth’s statement of "I think I should have a lawyer" or "Do I need a lawyer?" is an invocation of counsel under the Fifth Amendment, meaning that questioning of the youth should cease until the youth can consult with an attorney.

The Illinois Supreme Court upheld the blended sentencing scheme and held the youth did not unambiguously invoke his right to counsel.