John Tuy Pham and Chance Derrick Gonzales, Appellants v. the State of Texas

Summary

The Texas Court of Criminal Appeals affirmed the appellate courts' decisions that (1) a causal‑connection analysis under Article 38.23 is distinct from an attenuation‑of‑taint analysis, and (2) the initial burden of proving a causal connection between a Family Code § 52.02(b) violation and a confession rests on the defendant. The Court rejected the appellants' arguments that the burden should lie with the State and that the two analyses are the same, and noted a dissent disagreeing on those points.