In People v. Hogan (1982) 31 Cal.3d 815, the defendant was convicted and sentenced to death for murdering two members of a coworker's family. (Id. at pp. 820-822.) On automatic appeal to the California Supreme Court, defendant challenged the admission of a statement he made to police and subsequent statements he made to his wife. (Id. at p. 834.) He argued that his confession to the police was coerced from him by promises of help, false representations regarding the strength of the evidence against him, and suggestions by the interrogating officers that he had committed the crimes while mentally ill. (Ibid.) He challenged the ensuing statements he made to his wife on the ground that they were tainted by the illegality of his original confession to police. (Ibid.) The pertinent facts in Hogan were as follows: The police interrogated Hogan three times beginning shortly after his arrest. (Hogan, supra, 31 Cal.3d at p. 835.) During the first two interviews, he denied culpability for the crimes. (Id. at pp. 835-836.) After the second interview, Hogan was permitted to see his wife on two occasions, and both times their conversations were secretly recorded. (Id. at p. 836.) Hogan again denied committing any crimes, but he began to express uncertainty about whether he committed the homicides and whether he was crazy. (Ibid.) In their second conversation, Hogan's wife conveyed false information about the crime the police had provided to her, and suggested to him that she thought most of the facts pointed to his guilt. (Id. at pp. 837, 842.) Hogan was interviewed by police a short time later, and made incriminating statements. (Hogan, supra, 31 Cal.3d at p. 838.) Ten minutes after this interview concluded, Hogan was allowed to telephone his wife. (Id. at p. 828.) Both Hogan and his wife were advised that the conversation was being recorded. (Ibid.) Before she spoke to her husband, the police told Mrs. Hogan that he had admitted responsibility for the murders. (Ibid.) Hogan made further incriminating statements during the telephone conversation, and in a visit with his wife that was secretly recorded the next day. (Id. at pp. 827, 829.) In a lead and concurring opinion, four justices agreed in Hogan that the defendant's original confession to the police was involuntary, although they did not agree about the factual grounds for so holding. (Hogan, supra, 31 Cal.3d at p. 843 (lead opn.); id. at p. 855 (conc. opn. of Kaus, J.).) As to the court's further ruling that Hogan's statements to his wife were tainted by the confession he made to police, the lead opinion analyzed this issue in a single paragraph: "The determination that Hogan's third statement to the police was involuntary affects the admissibility of the two subsequent conversations with his wife. The first conversation, taped over the phone with the knowledge of Hogan and his wife, occurred just ten minutes after the completion of the third police interview. The second subsequent conversation took place the following morning at the jail. The rule of law governing repetitions of incriminating statements was stated in People v. Johnson (1969) 70 Cal.2d 541, 547-548: 'Where an accused makes one confession and then testifies or upon subsequent questioning again confesses, it is presumed that the testimony or second confession is the product of the first. ... The prosecution has the burden of showing a break in the causative chain. ...' There was no apparent intervening circumstance between Hogan's involuntary statement to the police and his subsequent In Hogan, the police consciously used Hogan's wife to support their efforts to elicit incriminating statements from him. Hogan was first permitted to visit with his wife after the police had made two unsuccessful attempts to obtain a confession. The police arranged for both visits to take place in a room where the conversations could be secretly recorded. By at least the second visit, Hogan's wife had been primed with information about the crimes, some of it false, that caused her to believe he was probably guilty. The police followed up the second visit with the interrogation in which Hogan first confessed to the crimes. From Hogan's point of view, the telephone call with his wife afterward was little more than a continuation of his police interrogation since he knew the police were recording it. In fact, the police had let Hogan's wife know that he had just confessed before permitting her to speak with him and recording their conversation. Thus, the hand of the police was evident in all of Hogan's conversations with his wife during this time period. Whether wittingly or unwittingly, Hogan's wife acted as an arm of the police, allowing them to continue to interrogate Hogan by means of questions posed by her. This was confirmed in the face-to-face conversation between Hogan and his wife on the morning following his confession to police. At that meeting, under questioning by his wife, Hogan stated that he still did not know whether he had committed the crimes, telling her at one point, "You keep asking me and I keep telling you I don't know. You're just like 'em." (Hogan, supra, 31 Cal.3d at p. 829.)