Alvarado v. State (1993)
In Alvarado v. State, 853 S.W.2d 17 (Tex. Crim. App. 1993), the Court noted two exceptions to that general rule.
A confession obtained by foreign officials will be excluded if the circumstances surrounding the confession "shock the conscience" of an American court. Id. at 21-22.
The confession will also be excluded if U.S. law-enforcement officials participate in the foreign interrogation, or if the foreign authorities are acting as agents for U.S. law enforcement. Id. at 22.
The Court of Appeals in this case applied Alvarado by analogy, holding that the circumstances of this case did not shock the conscience, and that the Chicago police were not acting as agents for Texas law enforcement. Nonn v. State, 13 S.W.3d at 439-440.
The Court of Appeals affirmed the trial court's judgment. Id. at 444.