1. Introduction

This consolidated Eleventh Circuit decision arises from a 2022 Coast Guard interdiction of a vessel encountered about 111 miles off the Dominican Republic in international waters. The vessel bore no indicia of nationality. Jose Leon-Marin identified himself as master and claimed Venezuelan nationality. When Venezuela “could neither confirm nor deny” the vessel’s nationality, the Coast Guard treated the vessel as “without nationality” under the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. § 70502(d)(1)(C), recovered 23 bales of cocaine (575 kilograms), and arrested the crew: Rodolfo Rodriguez Vazquez, Jose Leon-Marin, and Stanley Javier Cabrera.

The defendants pleaded guilty to MDLEA conspiracy (46 U.S.C. §§ 70503(a)(1), 70506(b); 21 U.S.C. § 960(b)(1)(B)) after the district court denied a motion to dismiss raising multiple constitutional and jurisdictional objections to the MDLEA’s reach and vessel-status provisions. On appeal, all three renewed MDLEA challenges; Vazquez and Cabrera also contested the denial of minor-role reductions under U.S.S.G. § 3B1.2(b).

The key issues were: (i) whether Congress may apply the MDLEA in another nation’s exclusive economic zone (EEZ) under the Felonies Clause; (ii) whether the MDLEA’s “vessel without nationality” definition is constrained by customary international law; (iii) whether due process requires a U.S. nexus for MDLEA prosecutions; (iv) whether an asserted defect in the “nationality vs. registry” inquiry defeats subject-matter jurisdiction; and (v) whether two crew members qualified as minor participants for sentencing.

2. Summary of the Opinion

The Eleventh Circuit affirmed. It held that existing circuit precedent foreclosed each constitutional and jurisdictional argument: the EEZ counts as “high seas” for Felonies Clause purposes; Congress is not limited by customary international law when defining “stateless vessel” under the MDLEA; no U.S. nexus is required for MDLEA prosecutions; and the statute treats “nationality” and “registry” as interchangeable for the vessel-status inquiry. The court also affirmed the district court’s denial of minor-role reductions for Vazquez and Cabrera, concluding they played a critical role in transporting a very large quantity of cocaine and stood to receive substantial compensation.

3. Analysis

3.1 Precedents Cited

The panel’s constitutional and jurisdictional rulings are almost entirely precedent-driven, explicitly relying on a line of Eleventh Circuit MDLEA cases:

• United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), cert. denied, 145 S. Ct. 2706 (2025): The court treated this as dispositive of the “EEZ is not high seas” theory, reaffirming that a nation’s EEZ “is part of the ‘high seas’ for purposes of the Felonies Clause.”
• United States v. Canario-Vilomar, 128 F.4th 1374, 1381 (11th Cir.), cert. denied, No. 25-5506 (U.S. Oct. 6, 2025): This case foreclosed the contention that customary international law limits Congress’s ability to define “stateless vessel” for MDLEA purposes. The panel quoted the rule that the Felonies Clause is “not limited by customary international law,” so international law cannot limit Congress’s statutory definition.
• United States v. Cabezas-Montano, 949 F.3d 567 (11th Cir. 2020): The panel relied on this decision both for standards of review and for the substantive holding that the MDLEA is a valid Felonies Clause exercise “as applied to drug trafficking crimes without a ‘nexus’ to the United States.”
• United States v. Campbell, 743 F.3d 802, 809-10 (11th Cir. 2014): Cited via Cabezas-Montano to reinforce that no nexus to the United States is required for MDLEA prosecutions.
• United States v. Gruezo, 66 F.4th 1284 (11th Cir.), cert. denied, 144 S. Ct. 178 (2023): Used to reject the late-raised “nationality vs. registry” subject-matter jurisdiction argument (holding the MDLEA treats “nationality” and “registry” as interchangeable), and also cited in the minor-role discussion for the defendant’s burden and the recurring conclusion that essential maritime couriers often do not qualify for § 3B1.2 relief.
• United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir. 1999) (en banc): The foundational Eleventh Circuit framework for mitigating-role determinations. The panel applied its two-part inquiry: (1) compare the defendant’s role to the relevant conduct attributed to him; and (2) compare his role to other participants involved in that relevant conduct.
• United States v. Valois, 915 F.3d 717, 732 (11th Cir. 2019): Cited alongside Gruezo and Cabezas-Montano as further support that maritime smugglers performing essential transport functions for substantial pay are not clearly entitled to minor-role reductions.

3.2 Legal Reasoning

(a) MDLEA reach in an EEZ. The defendants argued that the vessel was in the Dominican Republic’s EEZ and that an EEZ is not “high seas” under customary international law, placing the conduct outside Congress’s Felonies Clause power. The panel rejected the premise because United States v. Alfonso already held that an EEZ is treated as “high seas” for Felonies Clause analysis in this circuit. As a result, the location theory could not succeed.

(b) “Stateless vessel” definition vs. customary international law. The defendants attacked 46 U.S.C. § 70502(d)(1)(C), which authorizes treating a vessel as without nationality when the claimed nation of registry does not affirmatively corroborate nationality (here, Venezuela could neither confirm nor deny). They contended the statute exceeds Congress’s authority because the definition allegedly goes beyond “statelessness” as recognized by customary international law. The panel held that United States v. Canario-Vilomar forecloses this: the Felonies Clause is “not limited by customary international law,” so Congress may define “stateless vessel” for MDLEA jurisdiction even if international-law concepts differ.

(c) No U.S. nexus required. For the first time on appeal, the defendants argued that prosecuting them without any connection (“nexus”) to the United States violated due process and exceeded Felonies Clause authority. The panel invoked Cabezas-Montano (citing United States v. Campbell) to reaffirm that MDLEA prosecutions do not require a U.S. nexus in this circuit, rejecting both the due process framing and the Article I framing.

(d) Subject-matter jurisdiction and the “nationality vs. registry” claim. Also raised for the first time on appeal, defendants asserted that the master’s statement was a claim of “nationality,” not “registry,” and thus the statutory procedure was not met and jurisdiction failed. The panel applied United States v. Gruezo, which holds the MDLEA treats “nationality” and “registry” as interchangeable in § 70502. Therefore, the district court had subject-matter jurisdiction under the MDLEA and § 70502(d)(1)(C) applied.

(e) Minor-role reductions under U.S.S.G. § 3B1.2(b). Vazquez and Cabrera argued the district court focused too heavily on drug quantity and expected payment. The panel, using the clear-error standard, emphasized: (i) defendants bore the burden (Gruezo); (ii) the correct framework is Rodriguez De Varon plus the commentary factors in U.S.S.G. § 3B1.2 cmt. n.3(C); (iii) both defendants were held accountable for the conduct they personally undertook—transporting 575 kg by sea—and their participation was “critical” to accomplishing that relevant conduct; and (iv) the promised compensation (one million Dominican pesos) showed substantial expected benefit. In line with Rodriguez De Varon, Gruezo, Cabezas-Montano, and Valois, the panel held there was no “definite and firm conviction” the district court erred.

3.3 Impact

Although unpublished, the opinion underscores several practical realities in Eleventh Circuit MDLEA litigation:

• EEZ-based limits are largely unavailable in this circuit after United States v. Alfonso; defendants should expect MDLEA “high seas” challenges premised on EEZ geography to fail.
• Customary-international-law constraints arguments are unlikely to succeed in light of United States v. Canario-Vilomar; the statutory definition of “vessel without nationality” is treated as an exercise of Congress’s Felonies Clause power not cabined by customary norms.
• Nexus and due process challenges remain foreclosed by Cabezas-Montano / United States v. Campbell, keeping the MDLEA’s extraterritorial sweep broad.
• Minor-role reductions for maritime couriers remain difficult where defendants are entrusted with large quantities and are essential to transporting the drugs, especially if there is evidence of significant promised compensation; district courts retain wide latitude under clear-error review.

4. Complex Concepts Simplified

• MDLEA (Maritime Drug Law Enforcement Act): A federal statute criminalizing certain drug trafficking conduct on the high seas, including on vessels deemed “subject to the jurisdiction of the United States.”
• Felonies Clause (U.S. CONST. art. I, § 8, cl. 10): The constitutional provision empowering Congress to “define and punish” felonies committed on the high seas. The Eleventh Circuit reads this power broadly in MDLEA cases.
• Exclusive Economic Zone (EEZ): A maritime zone extending up to 200 nautical miles from a coastal state where that state has certain resource-related rights. In this circuit, an EEZ is treated as part of the “high seas” for Felonies Clause purposes (per United States v. Alfonso).
• “Vessel without nationality” / “stateless vessel”: Under 46 U.S.C. § 70502(d)(1)(C), a vessel can be treated as without nationality when a claimed nation of registry does not affirmatively verify the claim. If a vessel is “without nationality,” the MDLEA treats it as subject to U.S. jurisdiction.
• Subject-matter jurisdiction (in this setting): The court’s authority to adjudicate the federal offense. MDLEA jurisdiction often turns on statutory vessel-status findings (e.g., whether the vessel is “without nationality”).
• Minor participant (U.S.S.G. § 3B1.2(b)): A guideline reduction for defendants who are “substantially less culpable” than average participants. Courts apply a fact-intensive inquiry; being a courier does not automatically qualify, particularly when the courier’s function is essential and the drug quantity is large.

5. Conclusion

United States v. Stanley Cabrera reaffirms the Eleventh Circuit’s entrenched MDLEA framework: Congress may punish high-seas drug trafficking in a foreign EEZ; Congress’s “vessel without nationality” definition is not constrained by customary international law; MDLEA prosecutions do not require a U.S. nexus; and the statute’s “nationality” and “registry” terminology does not create a jurisdictional escape hatch. On sentencing, the decision reflects the circuit’s consistent reluctance to label essential high-seas transporters of very large cocaine loads as “minor participants,” particularly when substantial compensation is expected.