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

Summary

The Texas Court of Criminal Appeals affirmed the First Court of Appeals’ decisions affirming the admissibility of the defendants’ confessions. The majority held that a causal‑connection analysis under Article 38.23 is distinct from an attenuation‑of‑taint analysis and that the burden of proving a causal connection rests on the defendant. Justice Keasler dissented, arguing that the two analyses are the same and that the burden should lie with the State.