Cates v. State (1989)

In Cates v. State, 776 S.W.2d 170, 171-72 (Tex. Crim. App. 1989) the Texas Department of Human Resources ("DHR") investigator was an extension of the police, the court emphasized that the defendant was the central figure of a criminal investigation for child abuse and that the investigator's function in pursuing a child abuser was to enforce the laws of Texas by discovering abuse and reporting it to the police. See id. The court ended its discussion by noting that it was evident that the DHR investigator was conducting a criminal investigation and officially operating to assist police in enforcing the State's criminal laws. See Cates, 776 S.W.2d at 174.