Clarifying MDLEA Jurisdiction: EEZ Inclusion, Stateless Vessel Definition, and Nexus Irrelevance

Introduction

United States v. Genaro Sanchez is an Eleventh Circuit decision handed down on April 28, 2025. The case arose from Sanchez’s indictment under the Maritime Drug Law Enforcement Act (MDLEA) for conspiring to distribute cocaine aboard a vessel on the high seas. Sanchez challenged the district court’s jurisdiction on three fronts:

Whether conduct in Colombia’s Exclusive Economic Zone (EEZ) falls outside “the high seas” as contemplated by the MDLEA and the U.S. Constitution;
Whether the MDLEA’s definition of “vessel without nationality” exceeds Congress’s constitutional authority by capturing vessels that are not stateless under international law;
Whether due‐process principles require a factual nexus between the crime and the United States.

The government moved for summary affirmance, invoking binding Eleventh Circuit precedents. Sanchez opposed, noting pending petitions for rehearing and certiorari in related cases. The Court, per curiam, granted summary affirmance and rejected all three jurisdictional challenges.

Summary of the Judgment

The Eleventh Circuit affirmed Sanchez’s conviction and rejected his challenges:

The court held that EEZs are part of the “high seas” for purposes of the Felonies Clause (U.S. Const. Art. I, § 8, cl. 10), so MDLEA enforcement in an EEZ is permissible.
The MDLEA’s broad definition of “vessel without nationality”—including vessels whose claimed registry nation neither affirms nor denies nationality—is a valid exercise of Congress’s power and is not constrained by customary international law.
No due‐process violation arises from the absence of a U.S. nexus: the statute is justified by universal and protective jurisdiction principles, which permit extraterritorial reach.

Binding decisions in United States v. Alfonso (2024) and United States v. Canario‐Vilomar (2025) controlled the outcome. The court emphasized that grants of certiorari do not alter circuit precedent, and there is no overlooked‐argument exception to the prior‐panel rule. Summary affirmance was thus appropriate.

Analysis

Precedents Cited

United States v. Alfonso (104 F.4th 815, 11th Cir. 2024): The court held that (a) EEZs count as high seas under the Felonies Clause; (b) international law does not limit Congress’s power under that clause; and (c) the MDLEA’s extraterritorial application in EEZs is proper.
United States v. Canario‐Vilomar (128 F.4th 1374, 11th Cir. 2025): Reaffirmed Alfonso, rejecting challenges to the MDLEA’s definition of “vessel without nationality” and to due‐process nexus requirements.
Groendyke Transportation, Inc. v. Davis (406 F.2d 1158, 5th Cir. 1969): Established standards for summary disposition—appropriate where one party’s position is “clearly right as a matter of law.”
In re Bradford (830 F.3d 1273, 11th Cir. 2016) and Gissendaner v. Commissioner, Georgia Department of Corrections (779 F.3d 1275, 11th Cir. 2015): Emphasized that a Supreme Court grant of certiorari does not itself change circuit law.

Legal Reasoning

The court’s analysis proceeded in three steps, each invoking de novo review of jurisdiction and statutory interpretation:

EEZ as High Seas: Under the Felonies Clause, Congress may define and punish felonies on the high seas. Alfonso held that EEZs—territorial waters extending up to 200 nautical miles—remain “high seas” for constitutional purposes. Sanchez’s conduct in Colombia’s EEZ thus falls within U.S. jurisdiction under the MDLEA.
Definition of Stateless Vessel: The MDLEA defines “vessel without nationality” to include any vessel for which the claimed registry nation does not affirmatively assert nationality. Canario‐Vilomar upheld this definition, holding that Congress’s power to define offenses on the high seas is not limited by customary international‐law definitions of “stateless.” International law cannot constrain the statutory reach of the Felonies Clause.
Nexus and Due Process: Due‐process challenges to MDLEA’s extraterritorial reach were consistently rejected. The court reaffirmed that universal and protective jurisdiction doctrines suffice to justify prosecution of foreign nationals for maritime drug offenses, eliminating any requirement of a specific nexus to the United States.

Finally, the court stressed the binding nature of prior‐panel precedent and refused to entertain new or “overlooked” arguments. The possibility of rehearing or certiorari did not bar summary affirmance.

Impact

United States v. Sanchez cements a surge of decisions upholding the broad extraterritorial application of the MDLEA. Key implications include:

Law enforcement agencies may continue intercepting suspected drug vessels in foreign EEZs without fear of U.S. jurisdictional infirmities.
Prosecutors can rely on the MDLEA’s “vessel without nationality” definition to capture vessels that international law might deem registered but whose registry is not verified or recognized.
The decision reduces opportunities for defendants to challenge MDLEA prosecutions on jurisdictional or due‐process grounds, reinforcing universal and protective jurisdiction theories in maritime drug interdiction.

Complex Concepts Simplified

Exclusive Economic Zone (EEZ): A maritime zone extending up to 200 nautical miles from a country’s coast, where that state has special rights for resource exploration but not full sovereignty. Under U.S. constitutional interpretation, EEZs remain “high seas.”
Felonies Clause: Article I, Section 8, Clause 10 of the U.S. Constitution grants Congress power to “define and punish . . . felonies committed on the high seas.” It underpins the MDLEA’s reach.
Universal and Protective Jurisdiction: Doctrines allowing states to prosecute certain offenses—piracy or drug trafficking at sea—regardless of where they occur or the nationality of the offender, based on the belief that these crimes harm the international community or state interests.
Stateless Vessel: A ship without recognized nationality. The MDLEA defines this to include vessels whose registry claims are neither affirmed nor denied by the claimed state, preventing registry evasion.

Conclusion

United States v. Genaro Sanchez reaffirms the Eleventh Circuit’s unwavering support for a robust extraterritorial application of the MDLEA. By confirming that EEZs are high seas, upholding Congress’s expansive definition of stateless vessels, and rejecting nexus‐based due‐process challenges, the court eliminates significant jurisdictional hurdles. The decision strengthens U.S. maritime drug‐control efforts and signals to lower courts that MDLEA challenges on these grounds will meet swift summary affirmance.