Chavez v. State
In Chavez v. State, 9 S.W.3d 817, 819 (Tex. Crim. App. 2000), a police officer authorized by an agreement between several counties to investigate controlled-substance violations in the participating counties made an undercover cocaine buy from Chavez in a county that was not a party to the agreement. 9 S.W.3d at 818.
Chavez argued the cocaine should have been suppressed under article 38.23 because the officer had no authority to act in the county where he made the buy. Id.
The court of criminal appeals emphasized that Chavez claimed the cocaine should have been suppressed "solely because the officer obtained it from her outside the geographical boundaries set out in the Agreement. Chavez alleged no violation of any of her rights." Id.
The court rejected Chavez's argument, holding that only the parties to the agreement had standing to complain about the breach of the agreement. Id. at 819.