In State v. Rumfolo, 545 S.W.2d 752, 754, 20 Tex. Sup. Ct. J. 134 (Tex. 1976), the State initiated an action for the forfeiture of cash claimed as gambling proceeds. 545 S.W.2d at 754. Police officers obtained a search warrant, raided a dice game, searched the participants, and seized cash. Id. at 753. Return was made to the justice court, and the justice of the peace ordered forfeiture of the proceeds. Id. The proceeding was appealed to the county court at law and, after a trial de novo, that court ordered the cash forfeited to the State. Rumfolo v. State, 535 S.W.2d 16, 19 (Tex. Civ. App.--Houston 14th Dist.), rev'd 545 S.W.2d 752, 755, 20 Tex. Sup. Ct. J. 134 (Tex. 1976). The court of appeals reversed and rendered judgment that the State must return the proceeds, holding article 18.18(b) and (f) unconstitutional. Id. at 21. The Court reversed the judgment of the court of appeals and affirmed the judgment of the county court at law. 545 S.W.2d at 755. At issue in Rumfolo was whether article 18.18 satisfied procedural due process requirements. Id. at 754. The State had obtained a search warrant and presented testimony at the show cause hearing. Id. The respondents were present at the show cause hearing but offered no evidence. Id. The respondents argued that the State bore the burden of proof when attempting to deprive a person of property, just as the State bore the burden of proof when seeking to deprive a parent of parental rights. Id. The Court rejected the analogy to parental rights and concluded that "to require claimants to show the property or proceeds is not gambling equipment or gambling proceeds as the case may be, is compatible with the due process requirement that claimants receive notice and be afforded an opportunity to present their objections to such forfeiture." Id. At the same time, however, we also "construed Art. 18.18 to require the State to assume the burden to prove the proceeds were used in the gambling activity and to trace the money to the named respondents." Id. This statement from Rumfolo - coupled with our holding that requiring a claimant to show that property is not gambling equipment or gambling proceeds does not violate due process - has generated confusion concerning the proper allocation of the burden of proof in civil forfeiture proceedings. E.g., Hardy, 50 S.W.3d at 694 (stating that "we view Rumfolo as requiring the State to make a prima facie showing that the property in question is contraband subject to forfeiture"); Id. at 698 (Gray, J., concurring) (stating that the Rumfolo holding does not support placing the burden of proof on the State)