Eduardo Alvarado, Appellant v. the State of Texas, Appellee

Summary

The Court of Criminal Appeals of Texas affirmed the conviction of Eduardo Alvarado, holding that Miranda warnings do not apply to confessions obtained by foreign officials outside the United States unless those officials act as agents of U.S. law enforcement. The Court also found no agency relationship between the Mexican State Judicial Police and the El Paso Police, concluding that the trial court's finding was not an abuse of discretion. Two dissenting opinions argued that an agency relationship existed and that the confession should be excluded under Miranda and the Texas exclusionary rule.