Citing In re Joseph H. (2015) 237 Cal.App.4th 517 (Joseph H.), defense counsel contended "Gladys R. questions are designed to elicit an incriminating response" because they are "used by the government [to] establish a minor's capacity to commit crimes

Thus, a finding of capacity is a prerequisite to an adjudication of wardship for a minor under 14. [Citations.] The presumption of incapacity may be rebutted by the production of ' "clear proof" ' that the minor appreciated the wrongfulness of the conduct when it was committed. [Citation.] ' "[C]lear proof" ' means clear and convincing evidence. [Citation.]" (In re Joseph H. (2015) 237 Cal.App.4th 517, 538 (Joseph H.), citing, inter alia, In re Gladys R. (1970) 1 Cal.3d 855, 867 & In re Manuel L. (1994) 7 Cal.4th 229, 232.) On appeal, we review the entire record in the light most favorable to the judgment and affirm the juvenile court's finding that appellant understood the wrongfulness of his conduct if that finding is supported by substantial evidence.

B. Standard of review. A substantial evidence standard is used to review a juvenile court's ruling that a minor understood the wrongfulness of his or her actions. (In re Joseph H. (2015) 237 Cal.App.4th 517, 538.) "We review the entire record in the light most favorable to the judgment and affirm the trial court's findings that the minor understood the wrongfulness of his conduct if they are supported by substantial evidence—that is, evidence that is reasonable, credible, and of solid value—from which a reasonable trier of fact could have made the requisite finding under the governing standard of proof."

A "Gladys R. questionnaire" documents questions and responses "designed to determine if an arrestee under the age of 14 understands the wrongfulness of his or her actions, within the meaning of [Penal Code] section 26." (In re Joseph H. (2015) 237 Cal.App.4th 517, 529 (Joseph H.); In re Gladys R. (1970) 1 Cal.3d 855 (Gladys R.)

Two inquiries are essential to this determination: first, what are the circumstances surrounding the interrogation; and second, given those circumstances, would a reasonable person have felt he or she was not at liberty to terminate the interrogation and leave. (Thompson v. Keohane (1995) 516 U.S. 99, 112.)" (In re Joseph H. (2015) 237 Cal.App.4th 517, 530-531.) "Although no one factor is controlling, the following circumstances should be considered: '(1) [W]hether the suspect has been formally arrested; (2) absent formal arrest, the length of the detention; (3) the location; (4) the ratio of officers to suspects; and (5) the demeanor of the officer, including the nature of the questioning.' (People v. Forster (1994) 29 Cal.App.4th 1746, 1753.)

Substantial evidence is evidence that is "reasonable, credible, and of solid value," sufficient to allow a reasonable trier of fact to have made the requisite findings. (In re Joseph H. (2015) 237 Cal.App.4th 517, 538 (Joseph H.).) If one of the juvenile court's findings is not supported by substantial evidence, we will reverse for error if "it appears reasonably probable that, absent the error, the appellant would have obtained a more favorable result."

"[A]n officer's obligation to administer Miranda warnings attaches only where there has been such a restriction of freedom of movement as to render the suspect 'in custody.' " (Inre Joseph H. (2015) 237 Cal.App.4th 517, 530, citing Stansbury v. California (1994) 511 U.S. 318, 322 (Stansbury); see also In re Joseph R. (1998) 65 Cal.App.4th 954, 958 [Miranda applies only to custodial interrogations].) "For Miranda purposes, custodial status arises if a person has been 'taken into custody or otherwise deprived of his freedom of action in any significant way.'

“[A]n officer’s obligation to administer Miranda warnings attaches only where there has been such a restriction of freedom of movement as to render the suspect ‘in custody.’ ” (In re Joseph H. (2015) 237 Cal.App.4th 517, 530, citing Stansbury v. California (1994) 511 U.S. 318, 322 (Stansbury); see also In re Joseph R. (1998) 65 Cal.App.4th 954, 958 [Miranda applies only to custodial interrogations].) “For Miranda purposes, custodial status arises if a person has been ‘taken into custody or otherwise deprived of his freedom of action in any significant way.’

The totality of the circumstances approach is appropriate even when the interrogation involves a juvenile. (In re Joseph H. (2015) 237 Cal.App.4th 517, 533; see also J.D.B. v. North Carolina (2011) 564 U.S. 261.) While courts recognize a minor's age might make him more susceptible to outside pressure or influence, they also recognize a minor "has the capacity to make a voluntary confession."

“A commitment decision, especially a decision involving a minor with multifarious complex problems... cannot be driven by one problem.” (In re Joseph H. (2015) 237 Cal.App.4th 517, 543.) “Providing a child with an appropriate education is part of the treatment and rehabilitative services provided by [the DJJ], so any commitment to such a facility necessarily includes services for any special educational needs [citation], among other important considerations.