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 are not required for confessions obtained by foreign officials when those officials are not agents of U.S. law enforcement, and that the trial court did not abuse its discretion in finding no agency relationship. The confession was therefore admissible under Texas Code of Criminal Procedure article 38.23. Two dissenting opinions argued that an agency relationship existed and that the confession should be suppressed.