Imagine that a criminal suspect, indicted by the state of New\u00a0York on a murder charge, flees to Houston, Texas. The suspect\u2019s\u00a0freedom is short-lived; he is quickly recognized and arrested by Texas\u00a0State Police for the out-of-state warrant. A New York State Police\u00a0investigator then travels to Texas to take the defendant\u2019s statement\u2014not an unusual occurrence. Texas criminal procedure requires\u00a0investigators to inform criminal defendants of their right to end the\u00a0interview at any time before the investigator begins the interview. Texas\u00a0law also requires such interviews to be electronically recorded.\u00a0However, this investigator is from New York, and New York Criminal\u00a0procedure does not require either of these acts; predictably, the\u00a0investigator fails to do either of them. The defendant is later tried in\u00a0New York and convicted of murder. However, he appeals, arguing that\u00a0the statement he made in Texas was inadmissible because the\u00a0investigator failed to follow the procedures that Texas requires. How\u00a0should the court rule? Should New York law or Texas law apply?\u00a0The aforementioned situation is the exact fact pattern of People\u00a0v. Benson, a seminal New York state case that exemplifies a conflict of\u00a0criminal laws. Though the legal fields of Conflict of Laws and Criminal\u00a0Law generally do not intersect, when they do, the question frequently\u00a0at issue is whether evidence that is gathered properly under the rules of\u00a0one state but not of the other should be barred by the exclusionary rule.\u00a0This Essay argues that New York courts have resolved this issue\u00a0inconsistently: cases involving the same issues have resulted in opposite\u00a0outcomes. Moreover, the courts\u2019 opinions are often underexplained,\u00a0with over-reliance on precedent and general principles rather than\u00a0comprehensively analyzing the issues. Identifying and understanding\u00a0this defect can inform future decision-makers on how to improve the\u00a0clarity, consistency, and fairness of the criminal justice system going\u00a0forward. The paper concludes by proposing an alternative rule\u2014applying the law of the state whose law enforcement acted against the\u00a0defendant.<\/p>\n