MDLEA Jurisdiction Confirmed in Foreign EEZs: No Nexus Required, “Nationality” Equals “Registry,” and Nominal U.S. Interdiction Role Does Not Bar Prosecution

Case: United States v. Roberto Peralta Ibarra (No. 22-13655) & United States v. Alberto Peguero (No. 22-13743) (11th Cir., Jan. 13, 2026) (per curiam, not for publication).
Lower court: Southern District of Florida, D.C. No. 1:21-cr-20581-DPG-3 (Ibarra) & -2 (Peguero).
Disposition: Convictions affirmed; Peguero’s sentence affirmed.

1. Introduction

Roberto Peralta Ibarra and Alberto Peguero appealed their convictions under the Maritime Drug Law Enforcement Act (MDLEA) for conspiring to distribute controlled substances on a vessel alleged to be “subject to the jurisdiction of the United States.” Peguero also challenged his sentence, arguing he qualified for federal “safety valve” relief from a statutory mandatory minimum.

The appeal presented a familiar cluster of MDLEA challenges: whether an interdiction in a foreign state’s exclusive economic zone (EEZ) is “high seas” conduct for constitutional purposes; whether Congress may define “stateless” vessels beyond customary international law; whether due process requires a U.S. nexus when prosecuting foreign nationals for extraterritorial drug trafficking; whether the government established statutory jurisdiction under 46 U.S.C. § 70502(d)(1)(C); whether U.S. prosecution is improper when another nation allegedly “ran” the interdiction; and whether Peguero was disqualified from safety-valve relief by his criminal history.

2. Summary of the Opinion

The Eleventh Circuit affirmed across the board. The court held (largely by applying binding precedent) that:

An EEZ is part of the “high seas” for purposes of Congress’s Felonies Clause authority, so the MDLEA can reach conduct in Colombia’s EEZ.
International law does not limit Congress’s authority to define “stateless” vessels for MDLEA jurisdiction.
No due process “nexus” to the United States is required for MDLEA prosecutions of foreign nationals on the high seas.
For § 70502(d)(1)(C), a verbal claim of Dominican “nationality” sufficed because “nationality” and “registry” are interchangeable in the MDLEA under Eleventh Circuit precedent.
The alleged “nominal involvement” of U.S. authorities in a Dutch-led interdiction did not render the prosecution unconstitutional.
Peguero was ineligible for safety-valve relief because United States v. Pulsifer makes § 3553(f)(1)’s disqualifiers operate as a checklist—failing any one disqualifies the defendant.

3. Analysis

A. Precedents Cited (and How They Controlled the Result)

1) United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), cert. denied, 145 S. Ct. 2706 (2025)

What Alfonso held (as used here): A foreign EEZ counts as “high seas” for purposes of Congress’s Felonies Clause power, and “International law does not limit the Felonies Clause.”
How it controlled this appeal: Appellants’ core jurisdictional theory—“we weren’t on the high seas because we were in Colombia’s EEZ”—was treated as foreclosed. The panel characterized Alfonso as binding on the constitutional “high seas” question and therefore dispositive of MDLEA applicability.

2) United States v. Kluge, 147 F.4th 1291 (11th Cir. 2025)

Role in the opinion: Not an MDLEA merits case here, but cited for the Eleventh Circuit’s “prior panel precedent rule.”
How it mattered: It reinforced the court’s institutional constraint: once Alfonso decided the EEZ/high-seas issue, later panels must follow unless abrogated by the Supreme Court or by the Eleventh Circuit sitting en banc.

3) United States v. Canario-Vilomar, 128 F.4th 1374 (11th Cir. 2025), cert. denied, __ S. Ct. __, 2025 WL 2824488 (Oct. 6, 2025)

Two major contributions:
- Statelessness definition: International law does not limit Congress’s authority to define “stateless” vessels for MDLEA purposes, including under 46 U.S.C. § 70502(d)(1)(C).
- No-nexus due process argument: The MDLEA does not require a nexus to the United States; universal and protective principles justify extraterritorial reach.
How it controlled this appeal: The panel treated both the “MDLEA’s stateless-vessel definition is unconstitutional” argument and the “no U.S. nexus violates due process” argument as already rejected.
Additional procedural point: The case was also cited for the rule that a guilty plea does not waive the right to challenge the constitutionality of the statute of conviction—explaining why these issues were still reviewable.

4) United States v. Campbell, 743 F.3d 802 (11th Cir. 2014)

How it was used: Quoted (via Canario-Vilomar) for the proposition that “universal and protective principles” support the MDLEA’s extraterritorial reach without a U.S. nexus.
Doctrinal role: Serves as the older foundation in the circuit for rejecting nexus-based due process challenges to the MDLEA.

5) United States v. Gruezo, 66 F.4th 1284 (11th Cir. 2023)

Key statutory interpretation applied: The MDLEA treats “nationality” and “registry” as interchangeable throughout § 70502.
How it mattered here: Appellants argued § 70502(d)(1)(C) was not satisfied because their proffers said only that the master “made a verbal claim of Dominican nationality,” not registry. The panel used Gruezo to reject the distinction and to hold that the stipulated facts established statutory jurisdiction.
Jurisdictional framing: The opinion also relied on Gruezo to treat the MDLEA’s statutory jurisdictional requirement as a subject-matter-jurisdiction question and to explain that parties may stipulate to facts bearing on jurisdiction (even though they cannot stipulate to jurisdiction itself).

6) United States v. Pulsifer, 601 U.S. 124 (2024)

Holding applied: The three criminal-history disqualifiers in 18 U.S.C. § 3553(f)(1) function as an eligibility “checklist.” If the defendant fails any one item, safety-valve relief is unavailable.
How it resolved sentencing: Peguero had an undisputed prior three-point offense under § 3553(f)(1)(B), which—under Pulsifer—alone disqualified him regardless of the other items.

B. Legal Reasoning

1) Constitutional “high seas” and EEZs

The court treated the “EEZ is not high seas” argument as a constitutional attack on Congress’s power under the Felonies Clause. By invoking United States v. Alfonso, the panel adopted a rule that, for Felonies Clause purposes, the “high seas” includes foreign EEZ waters. The practical consequence is that defendants cannot defeat MDLEA prosecutions merely by showing the interdiction occurred in an EEZ rather than beyond it.

2) Stateless-vessel definition and international law limits

The appellants’ theory was that § 70502(d)(1)(C) defines “stateless” more broadly than international law permits and thus exceeds Congress’s power. The panel, following United States v. Canario-Vilomar, rejected the premise: international law does not constrain Congress’s definitional choices for MDLEA jurisdiction as framed in that subsection.

3) Due process and “no nexus” prosecutions

The panel again relied on Canario-Vilomar (and the quoted language from United States v. Campbell) to reaffirm that the MDLEA’s prohibitions apply without requiring proof of a U.S. nexus. The opinion characterizes this as “longstanding precedent” and treats the due process argument as “plainly foreclosed.”

4) Statutory subject-matter jurisdiction under § 70502(d)(1)(C)

Appellants attempted to create a textual gap between a “claim of registry” (the statute’s words) and their case’s “verbal claim of Dominican nationality” (the proffered facts). The panel closed that gap by applying United States v. Gruezo, which reads the MDLEA as using “nationality” and “registry” interchangeably. Under that approach, the master’s claim—paired with the asserted state’s failure to verify—satisfied § 70502(d)(1)(C).

5) “Nominal involvement” by U.S. authorities in a Dutch-led interdiction

Appellants argued that because the interdiction was effectively “Dutch-run,” it violated due process for the United States to prosecute. The panel rejected this on two tracks:

Doctrinal deficiency: Appellants cited no authority making prosecutorial power contingent on the degree of U.S. involvement in the seizure/detention.
Treaty context: The opinion invoked the United Nations Convention Against Illicit Traffic in Narcotic Drugs and Psychotropic Substances (CAIT), emphasizing Article 17’s mandate to “co-operate to the fullest extent possible” and the treaty’s encouragement of “joint teams,” thus treating multi-state operational collaboration as contemplated rather than constitutionally suspect.

6) Safety valve interpretation

The panel treated Peguero’s safety-valve argument as purely controlled by United States v. Pulsifer. With a prior three-point offense established, the court held he was ineligible, making further dispute about how “and” operates in § 3553(f)(1) unavailable in this circuit post-Pulsifer.

C. Impact

EEZ interdictions remain firmly within MDLEA reach in the Eleventh Circuit: By applying United States v. Alfonso, the opinion reinforces that EEZ geography is not a jurisdictional escape hatch under the Felonies Clause framing.
Continued insulation of MDLEA jurisdiction from international-law constraints: The opinion consolidates the circuit’s view (via Canario-Vilomar) that Congress may define “statelessness” for MDLEA purposes without being limited by customary international law definitions.
Nexus challenges remain non-starters: The decision further signals that due process nexus arguments are not merely losing but treated as foreclosed.
Lowered litigation leverage over “nationality” vs. “registry” wording: The adoption of Gruezo’s interchangeability principle in the § 70502(d)(1)(C) context discourages hyper-literal challenges based on how the claim is phrased in factual proffers.
Operational cooperation does not dilute prosecutorial authority: The “Dutch-interdiction” argument’s rejection suggests defendants will face an uphill battle attacking U.S. prosecutions simply because partner nations played a leading operational role.
Sentencing: Post-Pulsifer, defendants with any one § 3553(f)(1) disqualifier (especially a three-point prior) will often be categorically barred from safety-valve relief in MDLEA cases that carry mandatory minimums.

4. Complex Concepts Simplified

MDLEA (Maritime Drug Law Enforcement Act): A federal statute allowing the U.S. to prosecute certain drug trafficking conducted on vessels outside U.S. territory, if statutory “vessel jurisdiction” requirements are met.
Felonies Clause: A constitutional provision empowering Congress to “define and punish Piracies and Felonies committed on the high Seas.” The key fight here was what “high seas” includes.
EEZ (Exclusive Economic Zone): A maritime zone beyond a nation’s territorial sea where the coastal state has certain economic rights. The Eleventh Circuit treats EEZ waters as “high seas” for Felonies Clause purposes (per United States v. Alfonso).
“Stateless” vessel (MDLEA sense): A vessel treated as lacking nationality for MDLEA jurisdiction—importantly, the Eleventh Circuit holds Congress’s statutory definition is not limited by customary international law (per United States v. Canario-Vilomar).
“Nationality” vs. “Registry” under § 70502: While maritime practice can distinguish these ideas, the Eleventh Circuit reads the MDLEA as using them interchangeably (per United States v. Gruezo), so a “claim of nationality” can satisfy statutory language about “claim of registry.”
Protective and universal principles: International-law concepts used to justify a country regulating certain conduct beyond its borders because the conduct is universally condemned or threatens national interests. The Eleventh Circuit uses these principles to support MDLEA prosecutions without a U.S. nexus.
Safety valve (18 U.S.C. § 3553(f)): A statutory mechanism allowing courts to sentence below mandatory minimums if criteria are met. After United States v. Pulsifer, failing any single criminal-history condition in § 3553(f)(1) blocks eligibility.
Prior panel precedent rule: In the Eleventh Circuit, one panel must follow earlier panel holdings unless overruled by the Supreme Court or the Eleventh Circuit en banc (as referenced via United States v. Kluge).

5. Conclusion

This decision is best read as a consolidation opinion: it does not innovate so much as it applies—and thereby strengthens—the practical force of existing Eleventh Circuit and Supreme Court rules in MDLEA litigation. By relying on United States v. Alfonso, United States v. Canario-Vilomar, and United States v. Gruezo, the court reaffirmed that foreign EEZ interdictions can be prosecuted under the MDLEA, that international law does not restrict Congress’s MDLEA jurisdictional definitions, that no U.S. nexus is required, and that statutory jurisdiction cannot be defeated by semantic distinctions between “nationality” and “registry.” On sentencing, United States v. Pulsifer decisively foreclosed safety-valve eligibility for defendants with a qualifying three-point prior offense.