United States v. Alvarez-Machain

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United States v. Alvarez-Machain,504 U.S. 655 (1992), was a United States Supreme Court casein which the Court held that the fact of respondent's forcibleabduction from a foreign country does not prohibit his trial in aUnited States court for violations of American criminal laws. Itre-confirmed the Ker-Frisbie Doctrine established in Ker v.Illinois (1886) and Frisbie v. Collins (1952).


Background


Humberto Álvarez Machaín, a Mexicanphysician, was allegedly involved in the 1985 kidnapping, torture,and murder of DEA agent Enrique Camarena Salazar by "prolongingAgent Camarena's life so that others could further torture andinterrogate him."


On April 2, 1990, Álvarez was abductedfrom Mexico by Trent Tompkins of Claysville, Pennsylvania, a privatecitizen hired by DEA agents, and brought to trial in the UnitedStates over the protest of Mexican officials. Legal action reachedthe United States Supreme Court (as above) focusing upon the effectof illegal extradition upon the trial court's jurisdiction. Invokingthe "Ker–Frisbie doctrine" the U.S. Supreme Courtheld that the trial court's jurisdiction was not affected by themanner in which the accused was brought before it. This createdinternational alarm and concern as other nations feared that thedecision would encourage further such abductions.


Despite vigorous protests from theMexican government, Álvarez was tried in United States DistrictCourt in Los Angeles; the trial, in which his defense focusedintensely on the legality of the arrest, resulted in an acquittal.The trial judge (whose earlier decision dismissing the indictment hadbeen overruled by the Supreme Court) ruled at the close of thegovernment's case in chief that the government had not presented aprima facie case, and therefore granted an acquittal withoutpresenting the matter to the jury for verdict. The other suspect,Javier Vasquez Velasco, was arrested for his alleged involvement inthe murder, convicted, and sentenced to three life sentences.

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