United States v. Gilbert Louis Chavarria

Appellant Chavarria seeks reversal of his conviction of violating 18 U.S.C. § 2312 (transportation of a stolen motor vehicle in foreign commerce). Appellant’s only argument is that certain inculpatory statements that he made to Mexican police were improperly admitted at his trial.

Chavarria and a companion transported a Cadillac automobile from Los Angeles to Mexicali. While in Mexico, they were detained for investigation by Mexican authorities who had observed them drop a syringe from the car. The Mexican police contacted the California Highway Patrol who informed them that the Cadillac had been stolen. The Mexican police then questioned Chavarria, and he confessed to stealing and transporting the car. Appellant claims that the admission of his confession to the Mexican police was error because the Mexican police did not give him the warnings required by Miranda v. Arizona (1966) 384 U.S. 436 , 86 S.Ct. 1602 , 16 L.Ed.2d 694 .

The record contains nothing tending to show that Chavarria’s statement was in fact coerced. Therefore, to exclude this confession, he had to argue that the Miranda requirements are applicable to custodial interrogations performed by the police of foreign…