Barbara Ann Griffin, Appellant v. the State of Texas, Appellee

Summary

The Texas Court of Criminal Appeals reversed the Court of Appeals' decision that the juvenile's written confession was involuntary, reinstating the trial court's judgment. It held that the Family Code cannot define the federal due‑process analysis of a written confession and that the State need not prove the admissibility of the prior oral statement absent proof it caused the written confession. The court also declined to adopt the “cat‑out‑of‑the‑bag” theory as a per se rule of involuntariness.