In re Z.L.B.

In the trial of a juvenile for certain sexual or assaultive offenses, the Texas Family Code makes an “outcry” exception to the hearsay rule for “statements that describe the alleged violation that: (1) were made by the child who is the alleged victim of the violation; and (2) were made to the first person, 18 years of age or older, to whom the child made a statement about the violation.” Tex. Fam.Code § 54.031(b); see also Tex.Code Crim. Proc. art. 38.072 § 2(a) (containing a nearly identical provision applicable in adult criminal proceedings). We must decide who bears the burden to produce…