MDLEA Jurisdiction in Foreign EEZs: EEZ Treated as “High Seas,” Broad Stateless-Vessel Definition, and No U.S. Nexus Requirement

Case: United States v. Ronald Arregoces Barros (11th Cir. Jan. 7, 2026) (per curiam) (Not for Publication)

Publication posture. The panel marked the decision “NOT FOR PUBLICATION.” The opinion primarily applies binding Eleventh Circuit precedent under the prior-panel-precedent rule rather than announcing a novel doctrinal test. Its practical significance lies in consolidating, in one affirmance, multiple MDLEA jurisdiction and constitutional holdings from recent circuit cases.

1. Introduction

This appeal concerns the scope of U.S. criminal jurisdiction under the Maritime Drug Law Enforcement Act (“MDLEA”), 46 U.S.C. §§ 70503, 70506, over drug trafficking aboard vessels encountered far from U.S. territory. Ronald Mijail Arregoces Barros (“Arregoces”) was convicted (after a guilty plea to conspiracy) of conspiring to possess five kilograms or more of cocaine on board a vessel “subject to the jurisdiction of the United States.”

The Coast Guard interdicted a vessel bearing no indicia of nationality in the Caribbean Sea (about 233 nautical miles south of Santo Domingo). A crew member claimed Colombian nationality for the vessel; under a U.S.–Colombia bilateral arrangement, Colombia could neither confirm nor deny the vessel’s registration. The Coast Guard treated it as a “vessel without nationality” and recovered 798 kilograms of cocaine.

Arregoces raised four principal issues on appeal:

whether Congress’s Felonies Clause power reaches conduct in a foreign nation’s Exclusive Economic Zone (“EEZ”);
whether Congress exceeded the Felonies Clause by defining “vessel without nationality” in 46 U.S.C. § 70502(d)(1)(C) more broadly than “statelessness” under international law;
whether a “claim of nationality” (as opposed to “registry”) can trigger § 70502(d)(1)(C); and
whether due process (and/or Article I limits) requires a U.S. nexus for MDLEA prosecutions of foreign nationals.

2. Summary of the Opinion

The Eleventh Circuit affirmed. The panel held Arregoces’s arguments were foreclosed by binding circuit precedent:

EEZ as high seas / international law limits rejected: Under United States v. Alfonso and United States v. Canario-Vilomar, an EEZ is treated as part of the “high seas” for Felonies Clause purposes, and international law does not constrain Congress’s Felonies Clause authority as applied to MDLEA enforcement in EEZs.
Broad “vessel without nationality” definition upheld: Under Canario-Vilomar (building from Alfonso), international law cannot limit Congress’s authority to define “stateless vessel” for MDLEA purposes, including where the claimed nation can neither confirm nor deny registry.
“Nationality” and “registry” treated interchangeably: Under United States v. Gruezo and Alfonso, the MDLEA treats “nationality” and “registry” as interchangeable throughout § 70502; a verbal claim of nationality can be handled as a claim triggering § 70502(d)(1)(C).
No nexus requirement / due process satisfied: Under United States v. Campbell and reaffirmed in Canario-Vilomar, the MDLEA does not require a nexus to the United States; due process is satisfied because drug trafficking on stateless vessels on the high seas is universally condemned and the statute provides clear notice.

3. Analysis

3.1 Precedents Cited

Class v. United States

The panel cites Class v. United States, 583 U.S. 174 (2018), for the proposition that a guilty plea does not bar a defendant from challenging the constitutionality of the statute of conviction. This framing matters because Arregoces pleaded guilty after losing his motion to dismiss; Class preserves constitutional review despite the plea.

United States v. Alfonso

United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), cert. denied, 145 S. Ct. 2706 (2025), is the opinion’s central pillar. The panel uses Alfonso for three linked holdings:

International law does not limit the Felonies Clause (as the Eleventh Circuit understands the Clause’s domestic constitutional scope).
An EEZ is part of the “high seas” for Felonies Clause purposes, making MDLEA enforcement in EEZs “proper.”
Statelessness under § 70502(d)(1)(C) is satisfied where there is a verbal claim of nationality and the claimed nation “could not confirm or deny registry,” rendering the vessel stateless under the MDLEA.

In Arregoces’s case, these holdings collectively defeat (i) the argument that Venezuela’s EEZ is not the “high seas,” and (ii) the statutory-jurisdiction argument grounded in Colombia’s inability to confirm or deny.

United States v. Canario-Vilomar

United States v. Canario-Vilomar, 128 F.4th 1374 (11th Cir. 2025), is cited both as substantive authority and as a reinforcement of how strictly the circuit applies the prior-panel-precedent rule. The panel relies on Canario-Vilomar for:

rejecting the contention that Congress was constrained by international law when defining “stateless vessel” and “high seas” for MDLEA purposes;
rejecting the strategic “EEZ carveout” argument (i.e., trafficking inside an EEZ rather than the open ocean does not remove the conduct from Congress’s reach); and
holding that no-nexus/due-process challenges are “plainly foreclosed” by earlier cases like Campbell.

The opinion also quotes Canario-Vilomar on the Eleventh Circuit’s prior-panel-precedent rule (binding unless overruled by the Supreme Court or the en banc court) and its rejection of an “overlooked reason or argument” exception. That procedural commitment is dispositive here: Arregoces’s submissions were treated as attempts to relitigate questions already decided.

United States v. Gruezo

United States v. Gruezo, 66 F.4th 1284 (11th Cir.), cert. denied, 144 S. Ct. 178 (2023), is used to answer Arregoces’s effort to draw a sharp distinction between “nationality” and “registry” for MDLEA jurisdiction. Gruezo held the MDLEA treats these terms as interchangeable across § 70502, including the provision defining “[a] claim of nationality or registry.”

That interpretive move forecloses Arregoces’s argument that § 70502(d)(1)(C) cannot apply when a crew member makes a verbal “claim of nationality” (rather than “claim of registry”) and the claimed nation cannot confirm or deny registration.

United States v. Campbell

United States v. Campbell, 743 F.3d 802 (11th Cir. 2014), supplies the established Eleventh Circuit answers to “nexus” and due process challenges:

No nexus required: “universal and protective principles” support the MDLEA’s extraterritorial reach; the protective principle does not require proof of an actual or intended effect inside the United States.
Due process satisfied: prosecution of an alien captured on the high seas while drug trafficking does not violate due process because the MDLEA provides clear notice and drug trafficking aboard stateless vessels is universally condemned.

The panel characterizes Arregoces’s argument as “identical” to those already rejected in Campbell and reiterated as foreclosed in Canario-Vilomar.

3.2 Legal Reasoning

The opinion’s reasoning is structured less as an independent merits analysis and more as an exercise in vertical and horizontal stare decisis within the circuit:

Identify the constitutional and statutory claims. Arregoces framed the dispute around the Felonies Clause, international law concepts of “high seas” and “statelessness,” statutory text in § 70502(d)(1)(C), and due process limitations.
Match each claim to existing circuit holdings. The panel maps each issue to a prior Eleventh Circuit decision that has already resolved it (or resolved its premise), especially Alfonso and Canario-Vilomar.
Apply the prior-panel-precedent rule to foreclose reconsideration. The panel emphasizes it cannot revisit those holdings absent Supreme Court or en banc intervention, and that “overlooked argument” exceptions are “categorically rejected.”
Conclude that the vessel and conduct fall within the MDLEA’s jurisdictional predicates. Given the claim of nationality and the claimed nation’s inability to confirm or deny registry, the vessel is treated as “without nationality” under § 70502(d)(1)(C), rendering it “subject to the jurisdiction of the United States” under § 70502(c)(1)(A).

Notably, the panel also corrects (implicitly) a common litigation theme in MDLEA cases: defendants often attempt to constitutionalize international law definitions (EEZ vs. high seas; statelessness under customary law) as limits on Congress’s Article I powers. The Eleventh Circuit’s recent line of cases—applied here—treats those international law concepts as non-limiting for Felonies Clause analysis, at least as a matter of domestic constitutional interpretation within the circuit.

A minor drafting point: the opinion’s section numbering repeats “IV.” This has no legal consequence but underscores the opinion’s streamlined, non-precedential format.

3.3 Impact

Although unpublished, the decision has several practical effects in MDLEA litigation within the Eleventh Circuit:

Closes common jurisdictional avenues in EEZ cases. Defendants seized in (or near) foreign EEZs will face Alfonso/Canario-Vilomar-based foreclosures on “not the high seas” arguments.
Stabilizes the “cannot confirm or deny” pathway to statelessness. The panel treats the “cannot confirm or deny” response as sufficient under § 70502(d)(1)(C), consistent with recent circuit practice.
Reduces traction of text-based “nationality vs. registry” challenges. By reaffirming Gruezo’s interchangeability reading, the decision signals that semantic distinctions will not easily defeat MDLEA jurisdiction.
Reinforces no-nexus prosecutions against foreign nationals. The opinion maintains that the Eleventh Circuit will not impose a constitutional “minimum contacts” or “U.S. effects” requirement in MDLEA high-seas/stateless-vessel cases.

The larger doctrinal impact depends on whether other circuits or the Supreme Court revisit the relationship between the Felonies Clause, international law, and Congress’s definitional choices in the MDLEA. Within the Eleventh Circuit, however, the trajectory is clear: these questions are treated as settled.

4. Complex Concepts Simplified

MDLEA (Maritime Drug Law Enforcement Act): A federal statute criminalizing drug trafficking on certain vessels, including “vessels without nationality,” even when conduct occurs outside U.S. territory. See 46 U.S.C. §§ 70503(b), 70502(c)(1)(A).
“Vessel without nationality” (stateless vessel) under the MDLEA: A vessel can be treated as stateless if someone in charge makes a claim of registry (or, in this circuit’s reading, nationality/registry interchangeably) and the claimed nation does not “affirmatively and unequivocally” confirm nationality. 46 U.S.C. § 70502(d)(1)(C).
EEZ (Exclusive Economic Zone): A maritime zone beyond a country’s territorial sea where the coastal state has special resource-related rights. Arregoces argued this zone is not the “high seas”; the Eleventh Circuit (via Alfonso) treats EEZs as part of the “high seas” for Felonies Clause purposes in MDLEA cases.
Felonies Clause: Congress’s power “[t]o define and punish Piracies and Felonies committed on the high Seas.” U.S. Const. art. I, § 8, cl. 10. The Eleventh Circuit reads this power broadly and not limited by customary international law for the issues presented.
No “nexus” requirement: A “nexus” argument asserts the government must show some connection between the offense and the United States (e.g., intended U.S. destination). Under Campbell (and reaffirmed in Canario-Vilomar), the Eleventh Circuit does not require such a showing for MDLEA prosecutions involving stateless vessels on the high seas.
Prior-panel-precedent rule: In the Eleventh Circuit, later panels must follow earlier published panel holdings unless the Supreme Court or the en banc Eleventh Circuit overrules them. This rule drove the outcome: the panel treated Arregoces’s claims as already decided.

5. Conclusion

The Eleventh Circuit affirmed Arregoces’s MDLEA conspiracy conviction by straightforward application of binding precedent. The opinion reinforces four settled propositions in this circuit’s MDLEA jurisprudence: (1) enforcement in a foreign EEZ is permissible because an EEZ is treated as “high seas” for Felonies Clause purposes; (2) customary international law does not constrain Congress’s Felonies Clause authority in crafting MDLEA jurisdictional definitions; (3) “nationality” and “registry” are treated interchangeably for § 70502 analyses, including § 70502(d)(1)(C); and (4) neither Article I nor due process requires a nexus between the offense and the United States for high-seas/stateless-vessel drug trafficking prosecutions.