Felonies Clause Authority for the MDLEA Is Not Limited by International Law; No Evidentiary Hearing Required When MDLEA Jurisdiction Turns on Stipulated Facts

1. Introduction

United States v. Randar Vasquez Munoz addresses two recurring issues in Maritime Drug Law Enforcement Act (“MDLEA”) prosecutions: (1) whether Congress exceeded its constitutional authority under the Felonies Clause by criminalizing drug trafficking on the high seas, and (2) whether a district court must conduct an evidentiary hearing when a defendant challenges MDLEA “jurisdiction” over the vessel.

The case arose from a November 2020 Coast Guard interdiction in international waters roughly 115 nautical miles from Isla Malpelo, Colombia. The vessel had no flag, no registration documents, and no identifying markings. On boarding, the Coast Guard found three occupants and 11 bales later confirmed to contain 383 kilograms of cocaine. Although all three occupants claimed to be the master, none made a verbal claim of nationality in response to a Coast Guard request.

Munoz, a Costa Rican national, was indicted for MDLEA conspiracy and substantive possession with intent to distribute. He moved to dismiss on constitutional grounds and for lack of MDLEA jurisdiction, requesting an evidentiary hearing. The District Court denied the motion without a hearing; Munoz entered a conditional guilty plea preserving his right to appeal the denial. The Third Circuit affirmed.

2. Summary of the Opinion

3. Analysis

A. Precedents Cited

1) Constitutional review and presumption of validity

• Gov't of V.I. v. Steven, 134 F.3d 526 (3d Cir. 1998): Cited for the Third Circuit’s plenary review standard for constitutional challenges. Its role here is methodological—confirming the court reviews the MDLEA challenge without deference.
• United States v. Morrison, 529 U.S. 598 (2000): Supplies the principle that federal statutes are presumptively constitutional and invalidation requires a “plain showing” Congress exceeded constitutional bounds. The court uses Morrison to frame Munoz’s burden and to justify rejecting his Felonies Clause theory absent strong textual or historical support.

2) The Define and Punish Clause: textual structure and historical understanding

• United States v. Alarcon Sanchez, 972 F.3d 156 (2d Cir. 2020): Cited for labeling Article I, Section 8, Clause 10 as the “Define and Punish Clause” and for explaining its internal structure. This citation supports the Third Circuit’s move to parse Clause 10 into distinct grants of power.
• United States v. Smith, 18 U.S. (5 Wheat.) 153 (1820): Central authority for the proposition that Clause 10 contains three distinct powers (piracies, felonies on the high seas, and offenses against the law of nations) and that “felonies on the high seas” is distinct from “offences against the law of nations.” The Third Circuit relies on Smith to reject Munoz’s premise that the Felonies Clause is tethered to international law simply because another portion of Clause 10 is.
• United States v. Bellaizac-Hurtado, 700 F.3d 1245 (11th Cir. 2012): Cited as another articulation of the three separate grants of power in Clause 10. Its influence is structural: it reinforces that the constitutional inquiry depends on which sub-clause Congress invoked.
• United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), cert. denied, 145 S. Ct. 2706 (2025): Cited for the specific proposition that the Offenses Clause is limited by international law, but the Felonies Clause is not. The Third Circuit treats Alfonso as persuasive confirmation of the textual distinction it derives from Smith.

3) Evidentiary hearing standards (material factual dispute requirement)

• United States v. Hines, 628 F.3d 101 (3d Cir. 2010): Although a suppression-hearing case, it supplies a generally applicable rule: evidentiary hearings are needed only when there are disputed issues of material fact affecting the outcome; they do not resolve purely legal disputes. The Third Circuit uses Hines to conclude no hearing was needed where the relevant facts were stipulated.
• United States v. Mitchell- Hunter, 663 F.3d 45 (1st Cir. 2011): Applied directly to MDLEA jurisdiction challenges. It requires a “threshold showing” that material facts are in doubt or dispute before a hearing is warranted. The Third Circuit aligns with this approach and treats Munoz’s request as failing because he identified no genuine factual dispute.

4) Circuit split noted but not resolved: MDLEA “jurisdiction” vs Article III subject-matter jurisdiction

In a footnote, the Third Circuit acknowledges a split on whether the MDLEA’s “vessel subject to the jurisdiction of the United States” requirement implicates a federal court’s subject-matter jurisdiction or is instead a statutory/jurisdictional fact question.

• United States v. Prado, 933 F.3d 121 (2d Cir. 2019) and United States v. Gonzalez, 311 F.3d 440 (1st Cir. 2002): Cited as holding MDLEA jurisdictional requirements do not implicate subject-matter jurisdiction.
• United States v. Miranda, 780 F.3d 1185 (D.C. Cir. 2015), United States v. Tinoco, 304 F.3d 1088 (11th Cir. 2002), and United States v. Bustos-Useche, 273 F.3d 622 (5th Cir. 2001): Cited as holding the MDLEA’s jurisdictional requirements do act as a limitation on subject-matter jurisdiction.

The Third Circuit expressly “need not wade into” this dispute because, even on Munoz’s framing, the stipulated facts satisfied the MDLEA’s jurisdictional criteria.

B. Legal Reasoning

1) The Felonies Clause does not incorporate international-law constraints

Munoz’s core constitutional argument was that the MDLEA exceeds Congress’s power under the Felonies Clause because—he claimed—the Felonies Clause incorporates international law, and international law purportedly conflicts with the MDLEA’s assertion of authority over drug trafficking on the high seas.

The Third Circuit’s reasoning is primarily textual and structural:

• Article I, Section 8, Clause 10 contains three distinct grants of power. The court treats this as dispositive because the Offenses Clause explicitly references “the Law of Nations,” while the Felonies Clause does not.
• Because the Felonies Clause omits the “Law of Nations” reference, the court rejects the premise that Congress’s Felonies Clause authority is limited by international law in the same way Offenses Clause authority may be.
• Given the presumption of constitutionality (reinforced by United States v. Morrison), Munoz’s international-law-based premise could not “overcome the presumption of validity that attaches to the MDLEA as an act of Congress.”

Notably, the opinion does not undertake an extended analysis of customary international law or treaties; it resolves the argument at the level of constitutional text (Felonies vs Offenses) and the nature of Congress’s enumerated power.

2) No evidentiary hearing where the jurisdictional facts are stipulated

Munoz separately argued that the District Court was required to hold an evidentiary hearing on his motion to dismiss for lack of MDLEA jurisdiction. The Third Circuit rejected that claim by emphasizing the function of evidentiary hearings: they exist to resolve material factual disputes, not to provide a forum for legal argument on undisputed facts.

Applying United States v. Hines and United States v. Mitchell- Hunter, the court held there was no abuse of discretion because:

• The plea agreement contained stipulated facts material to MDLEA jurisdiction.
• The only disagreement was “the legal significance of the stipulated facts.”
• Therefore, there was no threshold showing of disputed material fact to justify a hearing.

3) The stipulated facts establish “vessel without nationality” under § 70502(d)(1)(B)

The court’s jurisdictional analysis turns on the MDLEA’s formal, exclusive methods for claiming nationality or registry under 46 U.S.C. § 70502(e): producing documents, flying a flag, or making a verbal claim. The parties stipulated the vessel had no documents, no flag, and that none of the occupants made a verbal claim of nationality after a Coast Guard request.

On that record, the Third Circuit concluded:

• The vessel qualified as a “vessel without nationality” under 46 U.S.C. § 70502(d)(1)(B) because the master/individual in charge failed, on request, to make a claim.
• A “vessel without nationality” is, by definition, “subject to the jurisdiction of the United States” under 46 U.S.C. § 70502(c)(1)(A).

The court also rejected Munoz’s attempt to pivot to 46 U.S.C. § 70502(d)(1)(C), reasoning it is inapplicable where no one made a claim of registry in the first place.

C. Impact

1) Constitutional challenges to the MDLEA in the Third Circuit

The opinion strengthens the MDLEA against a specific line of attack: arguments that Congress’s Felonies Clause authority is constrained by international law merely because the Offenses Clause is. By treating the textual difference as controlling, the Third Circuit signals that international-law incompatibility arguments will face long odds when the statute is defended as an exercise of the Felonies Clause power to “define and punish … Felonies committed on the high Seas.”

2) Practical litigation consequences for MDLEA jurisdiction disputes

The hearing holding is likely to matter operationally. Where the government can establish undisputed facts showing the absence of a nationality claim under § 70502(e), defendants may be unable to force an evidentiary hearing merely by characterizing the issue as “jurisdictional.” The decision encourages litigants and trial courts to separate (a) factual disputes about what occurred during interdiction from (b) legal disputes about what the MDLEA makes of those facts.

3) Unresolved but spotlighted: subject-matter jurisdiction split

By cataloging the split without resolving it, the Third Circuit preserves flexibility in future cases while alerting practitioners that the characterization of MDLEA “jurisdiction” remains contested nationally. Future Third Circuit panels may eventually have to decide whether a defect in § 70502(c) is waivable/forfeitable, what standard of review applies, and what procedural vehicles are appropriate—issues that can vary depending on whether the requirement is deemed to implicate Article III jurisdiction.

4. Complex Concepts Simplified

• “Define and Punish Clause” (Article I, § 8, cl. 10): A constitutional provision giving Congress power to criminalize certain conduct connected to the sea and international relations. The opinion emphasizes it contains three separate powers: piracies, felonies on the high seas, and offenses against the law of nations.
• Felonies Clause vs. Offenses Clause: The Offenses Clause expressly references “the Law of Nations” (international law), which can impose external limits. The Felonies Clause does not include that reference; the court treats that absence as decisive against importing international-law limits into Felonies Clause analysis.
• MDLEA “vessel without nationality”: Under 46 U.S.C. § 70502, nationality can be claimed only by documents, flag, or a verbal claim. If, upon request, the master/individual in charge does not make a claim, the vessel is treated as stateless—bringing it within U.S. jurisdiction under the MDLEA.
• Why “jurisdiction” can be confusing here: The MDLEA states that “[j]urisdiction … is not an element of an offense” and is decided by the judge as a “preliminary question[] of law.” That “jurisdiction” is statutory (whether the MDLEA applies), and courts disagree whether it also limits the court’s subject-matter jurisdiction.
• Evidentiary hearing: A proceeding to resolve disputed facts through testimony and exhibits. If the facts are agreed, courts generally decide the legal consequences without a hearing.

5. Conclusion

United States v. Randar Vasquez Munoz establishes two practical rules in the Third Circuit’s MDLEA jurisprudence: (1) the MDLEA is constitutionally supported by Congress’s Felonies Clause power, and that power is not textually constrained by international law in the way the Offenses Clause may be; and (2) when MDLEA jurisdiction depends on undisputed, stipulated interdiction facts, a district court may deny an evidentiary hearing and resolve the issue as a legal question. The decision is likely to narrow both the substantive and procedural avenues for challenging MDLEA prosecutions where statelessness is shown by the absence of any nationality claim under § 70502(e).