We show that the popular reinforcement learning (RL) strategy of estimating the state-action value (Q-function) by minimizing the mean squared Bellman error leads to a regression problem with confounding, the inputs and output noise being correlated. Hence, direct minimization of the Bellman error can result in significantly biased Q-function estimates. We explain why fixing the target Q-network in Deep Q-Networks and Fitted Q Evaluation provides a way of overcoming this confounding, thus sheddi...