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18 Brook. J. Int'l L. 303 (1992)
The Supreme Court Sanctions Transborder Kidnapping in United States v. Alvarez-Machain: Does International Law Still Matter

handle is hein.journals/bjil18 and id is 311 raw text is: RECENT DEVELOPMENTS
THE SUPREME COURT SANCTIONS
TRANSBORDER KIDNAPPING IN
UNITED STATES v. AL VAREZ-MA CHAIN:
DOES INTERNATIONAL LAW STILL
MATTER?
Steven M. Schneebaum*
When Enrique Camarena Salazar, a special agent of the
United States Drug Enforcement Administration (DEA) was
brutally murdered, apparently by the Mexican narcotics ring he
was investigating, United States law enforcement officials were
faced with a unique set of problems in apprehending his assas-
sins. That the killing was especially sadistic and grisly' at once
increased their frustration and strengthened their resolve to
bring the perpetrators to justice in the United States.
One of those alleged to have played a crucial rule in the
murder of Camarena was Humberto Alvarez-Machain. Alvarez, a
medical doctor in the tradition of Josef Mengele, is said to have
kept Camarena alive over a period of three days, during which
he was mercilessly tortured and interrogated until at last he
died.
Unable to obtain Alvarez by other means, the DEA ar-
ranged to have him abducted from his office in Guadalajara on
April 2, 1990. He was flown to El Paso, Texas, where he was
arrested. A grand jury in Los Angeles indicted him for his role in
* B.A. Yale, M.A. Oberlin, B.A. Oxon., M.C.L. (A.P.) G.W. Univ. Professorial Lec-
turer, School of Advanced International Studies, The Johns Hopkins University. Part-
ner, Patton, Boggs & Blow, Washington, D.C. Board of Directors, International Human
Rights Law Group.
1. See United States v. Caro-Quintero, 745 F. Supp. 599, 601-02 (C.D. Cal. 1990),
aff'd sub nom. United States v. Alvarez-Machain, 946 F.2d 1466 (9th Cir. 1991), rev'd,
112 S. Ct. 2188 (1992).

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