A-5156-07T4
12-01-08
We conclude a juvenile delinquency complaint, filed at the
direction of a county prosecutor's office, is not the
substantial equivalent of an indictment such that it initiates a
formal adversarial proceeding and triggers a juvenile's right to
counsel. We reverse the trial court's extension of the
protections of State v. Sanchez, 129 N.J. 261, 277 (1992) to
juvenile proceedings.
