EEZs as High Seas: Eleventh Circuit Reaffirms MDLEA Jurisdiction and Stateless-Vessel Definition

Introduction

In United States v. Benjamin Sandoval (consolidated with United States v. Martin Anthony Trench), the Court of Appeals for the Eleventh Circuit addressed two recurring challenges to the Maritime Drug Law Enforcement Act (MDLEA):

1. Whether narcotics offenses committed in a coastal nation’s Exclusive Economic Zone (EEZ) fall within the “high seas” for purposes of Congress’s power to “define and punish Felonies on the high Seas” under Article I, §8, cl. 10 of the U.S. Constitution.
2. Whether Congress exceeded its constitutional authority by extending MDLEA jurisdiction to certain vessels classified domestically as “without nationality,” even if international law might not label them stateless.

Defendants Trench and Sandoval were apprehended aboard a go-fast vessel in Colombia’s EEZ carrying large quantities of cocaine. They were convicted of conspiracy to possess with intent to distribute under MDLEA provisions, and appealed on jurisdictional and constitutional grounds. The Government moved for summary affirmance, arguing that existing Eleventh Circuit precedent foreclosed their claims.

Summary of the Judgment

The Eleventh Circuit (Judges Jordan, Luck, and Abudu, per curiam) summarily affirmed the convictions and granted the Government’s motion, holding:

• Binding precedents—United States v. Alfonso, United States v. Canario-Vilomar, and related cases—already establish that EEZ waters are part of the “high seas” for constitutional purposes, thereby authorizing Congress to legislate extraterritorially through MDLEA.
• The MDLEA’s domestic definition of a “vessel without nationality” is not constrained by customary international law, and Congress may constitutionally apply U.S. criminal jurisdiction to such vessels.
• No substantial question exists as to the correctness of the district court’s jurisdiction; the appeals therefore meet the standard for summary disposition under Groendyke Transportation, Inc. v. Davis.

Analysis

1. Precedents Cited and Their Influence

• United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024)
  – Held that EEZs are “high seas” under the Felonies Clause and that international law does not restrict Congress’s power. – Provided principal authority for rejecting the EEZ-based challenge.
• United States v. Canario-Vilomar, 128 F.4th 1374 (11th Cir. 2025)
  – Reaffirmed Alfonso; expressly stated that Congress need not align MDLEA definitions with international law and may reach conduct in EEZs.
• United States v. Nunez, 1 F.4th 976 (11th Cir. 2021)
  – Clarified that a vessel claiming multiple nationalities can be deemed stateless; customary international law does not set exhaustive conditions for statelessness.
• United States v. Bellaizac-Hurtado, 700 F.3d 1245 (11th Cir. 2012)
  – Distinguished off-territory drug offenses under the Offences Clause but confirmed MDLEA validity under the Felonies Clause, shaping the doctrinal baseline.
• Groendyke Transportation, Inc. v. Davis, 406 F.2d 1158 (5th Cir. 1969)
  – Provides the test for summary affirmance: when one side is “clearly right as a matter of law.”

2. Legal Reasoning

The Court employed a two-step—but largely precedent-driven—analysis:

1. High Seas Question
   • Article I’s Felonies Clause grants Congress power independent of international law constraints.
   • Under Alfonso, EEZs are treated as “high seas” for constitutional purposes, even though the U.N. Convention on the Law of the Sea (UNCLOS) affords coastal states limited resource rights within the EEZ.
   • Accordingly, narcotics trafficking in Colombia’s EEZ fell squarely within MDLEA coverage.
2. Stateless-Vessel Definition
   • The MDLEA defines “vessel without nationality” broadly, covering (i) vessels lacking documentation, (ii) vessels making conflicting claims, or (iii) vessels for which the claimed flag state fails to confirm nationality on request.
   • Because Congress is not bound by customary international law when legislating under the Felonies Clause, this domestic definition is constitutionally valid.
   • Nunez and Canario-Vilomar foreclose the argument that international criteria of statelessness must govern U.S. prosecutions.

Combining these points, the panel concluded that the Government’s jurisdictional theory was “clearly right,” warranting summary affirmance.

3. Potential Impact of the Judgment

• Circuit Entrenchment: By summarily affirming, the Eleventh Circuit cements a robust line of authority treating EEZ waters as high seas and upholding an expansive definition of statelessness. District courts within the circuit now have virtually no room to entertain EEZ-based or stateless-vessel challenges.
• Forum Shopping & Enforcement Strategy: Traffickers may shift routes to other circuits hoping for friendlier precedent, potentially prompting circuit splits that invite Supreme Court review.
• International Relations: The decision underscores unilateral U.S. enforcement even when UNCLOS or bilateral agreements might suggest otherwise. Foreign states may perceive this as jurisdictional overreach, enlivening diplomatic negotiations or protests.
• Broader Extraterritorial Criminal Law: Affirming that Congress’s Article I powers are not shackled by international law could influence other extraterritorial statutes (e.g., trafficking, terrorism, cybercrime), emboldening expansive jurisdictional reach.

Complex Concepts Simplified

• Exclusive Economic Zone (EEZ): A belt of sea extending up to 200 nautical miles from a coastal state’s baseline. The coastal state has sovereign rights to exploit resources but not full sovereignty as in territorial seas (12 nm). For constitutional purposes (per Eleventh Circuit), EEZ = high seas.
• High Seas: All parts of the ocean not included in a state’s territorial sea or internal waters. Traditionally a realm of limited national jurisdiction; however, Article I authorizes Congress to criminalize certain conduct there.
• Stateless (or “Vessel Without Nationality”): Under MDLEA, a vessel is stateless if it lacks valid registration, makes multiple or uncertain citizenship claims, or fails to receive flag-state confirmation. Stateless vessels are universally subject to boarding and enforcement.
• Summary Affirmance: A streamlined appellate disposition used where binding precedent makes the outcome obvious, preserving judicial resources.
• Prior-Panel Precedent Rule: An Eleventh Circuit doctrine requiring panels to follow earlier published decisions unless overruled by the en banc court or the Supreme Court.

Conclusion

United States v. Benjamin Sandoval adds yet another brick to the Eleventh Circuit’s jurisprudential wall supporting the MDLEA’s extraterritorial reach. The Court:

1. Affirmed that offenses within any nation’s EEZ fall under congressional authority to punish “felonies on the high seas.”
2. Confirmed Congress’s freedom to craft a domestic, broader-than-international definition of “vessel without nationality.”
3. Signaled that challenges based on international law norms will not gain traction in this circuit absent Supreme Court intervention.

In practical terms, the decision empowers U.S. drug-interdiction forces to act aggressively in EEZ waters and against quasi-flagged vessels, while legally reinforcing a doctrine that extraterritorial criminal statutes are measured primarily against the Constitution, not customary international law. Practitioners should anticipate swift summary dispositions of similar appeals and advise clients accordingly.