1. It has even been argued that "prior criminal experience can be a valid proxy for the knowledge and intelligence necessary to waive one's Fifth Amendment rights to silence and counsel;N.Y. App. Div,1995
2. Words Without Meaning: The Constitution, Confessions, and Mentally Retarded Suspects, 69 U;Morgan Cloud;Cm. L. REV,2002
3. providing a summary of research on the effects of certain factors on Miranda warning comprehension;. ' See Id;CALiF. L. REv,2008
4. Psychiatric Patients' Comprehension ofMiranda Rights;G Virginia;HUM. BEHAV,2008