Case Brief: United States V. Alvarez-Machain, 504 U.S. 655 (1992)
Facts
In 1990, the DEA kidnapped a Mexican citizen and doctor named Humberto Alvarez-
Machain from Guadalajara, Mexico, and brought him to the United States (Dwyer, 2015, p. 340).
It followed an indictment against Alvarez for his roles in the abduction and murder of DEA agent
Enrique Camarena Salazar and a Mexican Pilot in 1985. Doctor Alvarez was suspected of
participating in Officer Camarena’s murder and torture. His medical work enabled cartel
members to torture and interrogate Camarena by extending his life. Although there was an
extradition pact between the United States and Mexico, Alvarez was not deported. He was
kidnapped and transported to El Paso, Texas, where the DEA apprehended him. Alvarez filed a
request to have the prosecution against him thrown out, arguing that his abduction violated the
extradition treaty.
Procedural History
Although no DEA agents were directly engaged in Alvarez’s kidnapping, a federal judge ruled
that the agency was still at fault. To get his charge thrown out, Alvarez argued that his
kidnapping was absurd. Political behavior. According to Alvarez, his kidnapping was illegal
since it contradicted the terms of his extradition. The District Court did not have jurisdiction
since the case involved a treaty between the United States and Mexico. Since the respondent’s
abduction violated the extradition treaty, the District Court ruled it lacked jurisdiction to try him.
Alvarez was released and sent home by the District Court, returning to Mexico. The Court of
Appeals upheld the lower Court’s decision to dismiss the indictment and order Alvarez’s
2
Case Brief: United States V. Alvarez-Machain, 504 U.S. 655 (1992)
repatriation and the lower Court’s determination that the United States had ordered Alvarez’s
kidnapping.
RULES
The Supreme Court considered this case first United States v Rauscher, 119 U.S. 407. In that
case, the Court dealt with allegations of breach of an extradition treaty because of a forceful
abduction. As a result, the state could not charge defendant Rauscher with any more previously
transferred crimes. This prompted the judge to look into the Webster-Ashburton Treaty of 1842,
which set the rules for rendition between the United Kingdom and the United States. The debate
was about whether or not this. The attorney issued a ruling and stated that the Court may only try
him for one of the crimes listed for a person who had been taken extradition pact. For the crime
with which he is accused in the extradition procedures, as well as following the terms of that
treaty.
Application/Analysis
The Supreme Court agreed to hear the case on review and ultimately decided there had been
no violation of the treaty between the United States and Mexico. Therefore, the trial could
proceed in the United States with Mr. Alvarez-Machain as the defendant since Alvarez-Machain
is the defendant. Since Alvarez-Machain was taken from his home, it did not breach the treaty
when a person was forcibly removed from his nation and arrested upon arrival in the United
3
Case Brief: United States V. Alvarez-Machain, 504 U.S. 655 (1992)
States. Which ultimately led to his trial. In addition, the Court emphasized that the pact to be
apparent is that you aren’t only avoiding kidnapping. You’re also preventing abduction by force
illegally. The matter was remanded back to the trial court. Ultimately, Mr. Alvarez-Machain was
found not guilty and sent back to Mexico.
Conclusion
If anything were to happen to you when you were in another nation on official U.S. business, I
believe you should still be protected by American law. In my mind, a U.S. citizen is any man or
woman subject to the government of the United States. Officers assaulted, injured, or murdered
while on the job have their assailants treated as if they had launched an attack within the United
States. Consequently, I believe Mr. Alvarez-Machain Would have been punished and found liable
for abduction, beating, and ultimately killing that DEA agent and the poet working with him.
References
United States v. Alvarez-Machain, 504 U.S. 655 (1992)
https://supreme.justia.com/cases/federal/us/504/655/
4
