MDLEA Jurisdiction in Foreign Exclusive Economic Zones and Stateless Vessels After United States v. Jimenez‑Flores

I. Introduction

This consolidated, unpublished decision of the United States Court of Appeals for the Eleventh Circuit (United States v. Estupinan, United States v. Bautista‑Feliciano, and United States v. Jimenez‑Flores, Nos. 23‑12067, 23‑12114, 23‑12137) arises from a maritime drug interdiction in the Dominican Republic’s Exclusive Economic Zone (EEZ). The defendants were convicted of:

Conspiracy to possess with intent to distribute cocaine on board a vessel subject to the jurisdiction of the United States; and
Possession with intent to distribute cocaine on board such a vessel,

in violation of the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. §§ 70503, 70506.

On appeal, the three defendants raised a cluster of challenges:

Pre‑presentment delay and right to counsel: Ramon Bautista‑Feliciano argued his indictment should be dismissed because of governmental delay in (a) presenting him to a magistrate judge and (b) obtaining a criminal complaint. Jose Hugo Estupinan argued for dismissal because he was allegedly denied his Sixth Amendment right to counsel at a critical stage.
MDLEA jurisdiction in a foreign EEZ: All three appellants argued the United States lacked authority under the MDLEA to prosecute a felony committed in the Dominican Republic’s EEZ, contending that this was beyond Congress’s power under the Constitution’s Felonies Clause.
Proof that the vessel was “without nationality”: Alcibiades Jimenez‑Flores argued there was no subject‑matter jurisdiction because the government had not proven that the intercepted vessel was “without nationality” under the MDLEA.
Due process and lack of U.S. nexus: Bautista‑Feliciano and Jimenez‑Flores claimed that applying the MDLEA to their conduct—occurring on the high seas with no connection to the United States—violated the Fifth Amendment’s Due Process Clause.

The Eleventh Circuit rejected all of these arguments and affirmed the convictions. Although the opinion is “NOT FOR PUBLICATION” and thus non‑precedential in the Eleventh Circuit, it is significant for how it:

Applies the guilty‑plea waiver doctrine in the wake of Class v. United States,
Reaffirms that foreign EEZs are treated as “high seas” for Felonies Clause purposes,
Illustrates how “statelessness” can be established under the MDLEA, and
Reiterates that no U.S. nexus is required for MDLEA prosecutions of drug trafficking on the high seas.

II. Summary of the Opinion

A. Waiver of Pre‑Plea Constitutional Claims by Guilty Pleas

Estupinan and Bautista‑Feliciano had entered unconditional, valid guilty pleas. Relying on Supreme Court and Eleventh Circuit precedent, the panel held that such pleas waive virtually all non‑jurisdictional objections to pre‑plea government misconduct—even constitutional ones, including:

Alleged delay in presentment to a magistrate judge and delay in filing a complaint; and
Alleged denial of the Sixth Amendment right to counsel at a critical stage.

Because neither defendant challenged the voluntariness or validity of his plea, the court deemed these issues waived and declined to reach their merits.

B. MDLEA Jurisdiction in the Dominican Republic’s EEZ

The defendants argued that Congress lacked authority under Article I, Section 8, Clause 10 (the “Define and Punish” or “Felonies” Clause) to criminalize their conduct because the vessel was intercepted within the Dominican Republic’s EEZ, not on the “high seas.”

The Eleventh Circuit held that its recent published decisions—United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), and United States v. Canario‑Vilomar, 128 F.4th 1374 (11th Cir. 2025)—squarely foreclose that argument:

A nation’s EEZ is part of the “high seas” for purposes of Congress’s Felonies Clause power; and
Congress’s authority under the Felonies Clause is not limited by customary international law in defining the scope of the MDLEA.

Bound by its prior‑panel‑precedent rule, the court held that enforcement of the MDLEA in EEZs is constitutionally proper and rejected the jurisdictional challenge.

C. Stateless Vessel and Subject‑Matter Jurisdiction

Jimenez‑Flores attacked subject‑matter jurisdiction on the ground that the government had not proven the vessel was “without nationality.” The court reviewed the MDLEA’s statutory framework governing what constitutes a “vessel without nationality” and the circumstances under which a vessel is “subject to the jurisdiction of the United States.”

The panel highlighted:

The absence of any indicia of nationality (no flag, no registration documents, no markings);
The crew’s failure to identify a master or individual in charge; and
The complete absence of any claim of nationality when questioned.

Crucially, these were not contested facts: Jimenez‑Flores admitted them in his factual proffer and in the presentence investigation report (PSR). Under Eleventh Circuit precedent such as United States v. Nunez, 1 F.4th 976 (11th Cir. 2021), those facts sufficed to classify the vessel as stateless and thus “subject to the jurisdiction of the United States.” The court therefore rejected the jurisdictional challenge.

D. Due Process and the Lack of a U.S. Nexus

Finally, Bautista‑Feliciano and Jimenez‑Flores argued that applying the MDLEA to foreign nationals engaged in conduct with no connection to the United States violates due process. Citing United States v. Campbell, 743 F.3d 802 (11th Cir. 2014), Cabezas‑Montano, and Canario‑Vilomar, the panel held that this argument is squarely foreclosed:

The MDLEA does not require a nexus to the United States;
The statute’s extraterritorial reach is supported by the “universal” and “protective” principles of international law; and
As‑applied challenges based on lack of nexus have consistently failed in the Eleventh Circuit.

The court thus concluded that the MDLEA’s application to these defendants comported with due process.

All convictions were affirmed.

III. Detailed Analysis

A. Precedents on Guilty Pleas and Waiver

1. The governing doctrine

The court grounds its waiver analysis in a series of Supreme Court and circuit decisions:

Class v. United States, 583 U.S. 174 (2018) – A guilty plea does not automatically bar a defendant from raising certain facial constitutional challenges to the statute of conviction (for example, that the statute itself is invalid). But Class also recognizes a longstanding rule: a guilty plea generally waives challenges to the constitutionality of case‑related government conduct occurring before the plea.
United States v. De La Garza, 516 F.3d 1266 (11th Cir. 2008) & United States v. Pierre, 120 F.3d 1153 (11th Cir. 1997) – An unconditional guilty plea that is knowing and voluntary, and entered with the benefit of competent counsel, waives all non‑jurisdictional defects, including constitutional challenges to the conviction.
United States v. Castillo, 899 F.3d 1208 (11th Cir. 2018) – A defendant who pleads guilty cannot “complain about the specific facts of his detention,” underscoring that pre‑plea detention‑related issues are waived.
United States v. Williams, 29 F.4th 1306 (11th Cir. 2022) – A guilty plea may waive even claims of “structural error,” the most serious category of constitutional violations (e.g., total denial of counsel).
United States v. Gayden, 977 F.3d 1146 (11th Cir. 2020) & United States v. Lyons, 403 F.3d 1248 (11th Cir. 2005) – Define and apply the abuse‑of‑discretion standard for reviewing denials of motions to dismiss indictments.

Together, these authorities embody a strong rule: once a defendant voluntarily and unconditionally admits guilt in open court, he ordinarily forfeits the right to later attack preceding procedural or constitutional defects, unless he reserved those issues via a conditional plea or directly challenges the plea’s validity.

2. Application to delay and right‑to‑counsel claims

Against this background, the panel had little difficulty concluding that:

Delay in presentment and in obtaining a complaint (Bautista‑Feliciano); and
Alleged denial of counsel at a critical stage (Estupinan),

were non‑jurisdictional, pre‑plea issues that were waived by their unconditional guilty pleas. The defendants did not argue that their pleas were involuntary, uninformed, or conditional. Nor did they claim that the MDLEA itself was facially unconstitutional or that the indictment failed to state an offense—challenges that, under Class, can sometimes survive a guilty plea.

Because the pleas were valid and unconditional, the court did not even reach the merits of the alleged misconduct. This is a textbook application of the guilty‑plea waiver doctrine.

3. Practical implications

For defense counsel, the opinion reinforces several practice points:

If the defense intends to preserve pre‑plea issues (e.g., denial of counsel, delay in presentment, suppression issues), it must negotiate a conditional guilty plea under Fed. R. Crim. P. 11(a)(2), expressly reserving those issues for appeal.
Absent such a reservation, an unconditional plea will almost certainly waive any challenge to pre‑plea government conduct, even if grounded in the Sixth Amendment or involving alleged structural error.

B. MDLEA Jurisdiction and Congress’s Felonies Clause Power

1. Constitutional framework

The opinion begins its MDLEA discussion by parsing Article I, Section 8, Clause 10 of the Constitution, which gives Congress three distinct powers:

To define and punish piracies (the Piracies Clause);
To define and punish felonies committed on the high seas (the Felonies Clause); and
To define and punish offenses against the law of nations (the Offences Clause).

The MDLEA is justified as an exercise of the Felonies Clause. The statute criminalizes, among other things, knowingly or intentionally possessing with intent to distribute controlled substances on board a “vessel subject to the jurisdiction of the United States,” and conspiracy to commit that offense. See 46 U.S.C. §§ 70503(a)(1), (e)(1), 70506(b).

2. The status of EEZs under Eleventh Circuit precedent: Alfonso and Canario‑Vilomar

The defendants’ core argument was that Congress’s Felonies Clause power is limited to the “high seas” as defined by international law, which—so they claimed—does not include a foreign nation’s EEZ. The Eleventh Circuit rejected that contention as squarely inconsistent with binding precedent:

United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024)
- Held that an EEZ is part of the “high seas” for purposes of the Felonies Clause.
- Explicitly concluded that “international law does not limit the Felonies Clause,” meaning Congress is not constrained by customary international law when defining felonies on the high seas in domestic criminal legislation.
- Upheld the MDLEA as a valid exercise of Felonies Clause authority, including its application in EEZs.
United States v. Canario‑Vilomar, 128 F.4th 1374 (11th Cir. 2025)
- Reaffirmed that Congress was not constrained by international law in defining “stateless vessels” or the boundaries of the high seas for MDLEA purposes.
- Rejected the contention that the MDLEA could not reach a defendant simply because he trafficked drugs in a foreign nation’s EEZ (e.g., Colombia’s EEZ) rather than further out at sea.
- Reiterated the Eleventh Circuit’s prior‑panel‑precedent rule, emphasizing that panels are bound by earlier precedent and that there is no “overlooked argument” exception to that rule.

Because both Alfonso and Canario‑Vilomar are published and have not been overruled by the Supreme Court or by the Eleventh Circuit en banc, the panel in this case was strictly bound to follow them.

3. Application to the Dominican Republic’s EEZ

The appellants’ argument—that their conduct occurred in the Dominican Republic’s EEZ and therefore outside the Felonies Clause’s reach—was straightforwardly foreclosed by Alfonso and Canario‑Vilomar. The court held:

An EEZ (including the Dominican Republic’s) is part of the “high seas” for Felonies Clause purposes; and
Enforcement of the MDLEA in EEZs is constitutionally proper.

The prior‑panel‑precedent rule prevented the panel from entertaining any effort to relitigate these issues, even if the appellants offered new or refined arguments. As the court quoted, the Eleventh Circuit has “categorically rejected an overlooked reason or argument exception” to that rule.

C. Stateless Vessels, MDLEA Jurisdiction, and Proof at Sentencing

1. Statutory framework: “vessel subject to the jurisdiction of the United States”

The MDLEA applies to conduct on a “vessel subject to the jurisdiction of the United States,” a defined statutory term that includes a “vessel without nationality.” 46 U.S.C. § 70502(c)(1)(A).

A “vessel without nationality” includes, among other categories:

“A vessel aboard which the master or individual in charge fails, on request of [U.S. enforcement officers], to make a claim of nationality or registry for that vessel,” § 70502(d)(1)(B); and
“A vessel aboard which no individual, on request of [U.S. enforcement officers], claims to be the master or is identified as the individual in charge, and that has no other claim of nationality or registry” through documents or flag, § 70502(d)(1)(D) (cross‑referencing § 70502(e)).

A “claim of nationality or registry” can be made by, among other methods:

Possession and production of documents evidencing nationality; or
Flying the vessel’s national flag. 46 U.S.C. § 70502(e)(1)-(2).

The statute also directs that whether a vessel is “subject to the jurisdiction of the United States” is a jurisdictional question of law, not an element of the offense, and must be decided by the judge. 46 U.S.C. § 70504(a); see United States v. Iguaran, 821 F.3d 1335, 1336–37 (11th Cir. 2016).

2. Precedents on stateless vessels

The panel canvasses a line of Eleventh Circuit cases clarifying when a vessel is stateless under the MDLEA:

United States v. De La Cruz, 443 F.3d 830 (11th Cir. 2006) – The court upheld a statelessness finding where:
- The vessel flew no flag and carried no registration paperwork;
- It bore no markings indicating nationality;
- The captain concealed himself among the crew and never identified himself or the vessel’s nationality despite repeated questioning; and
- No crew member made any claim of nationality.
Under these circumstances, the vessel was “without nationality” and subject to U.S. jurisdiction.
United States v. De La Garza, 516 F.3d 1266 (11th Cir. 2008) – The defendant stipulated that no flag was flown and there were no indicia of nationality, and he pled guilty after acknowledging that the United States claimed jurisdiction. The court treated the stipulated absence of nationality indicia as sufficient to support a statelessness finding.
United States v. Cabezas‑Montano, 949 F.3d (11th Cir. 2020) – Coast Guard officers asked the crew to identify the master but no one did so, and no one responded when asked whether anyone wished to claim nationality for the vessel. The Eleventh Circuit held that this questioning was sufficient under § 70502(d)(1), even though the Coast Guard did not use the precise statutory phrase “individual in charge.” If the master or person in charge chose to remain silent, that silence could not defeat statelessness.
United States v. Nunez, 1 F.4th 976 (11th Cir. 2021) – Coast Guard officers approached a vessel with four men; when asked who was the pilot or master, one crew member replied that they all took turns. No one claimed to be master; there were no registry papers, no flag, and no markings. The court held:
- The vessel was stateless under the MDLEA because no one—master or crew—claimed nationality and there were no indicia of nationality;
- The Coast Guard was not required to ask further questions about nationality after no one claimed to be master; and
- International law provides no rigid script of questions that must be asked; a flexible, fact‑specific approach applies.

These cases collectively emphasize that a vessel’s statelessness is assessed by the totality of circumstances, focusing on:

Absence of flag or registry documents;
Absence of nationality markings; and
Failure of any individual to assert the vessel’s nationality when prompted.

3. Role of admissions and stipulations: Iguaran

In Iguaran, the Eleventh Circuit distinguished between:

Stipulating to jurisdictional facts (e.g., “no flag was flown,” “no documents were on board,” “no one claimed nationality”), which is permissible; and
Stipulating to jurisdiction itself (e.g., “the court has jurisdiction”), which is not binding on a court because jurisdiction is a pure question of law for the judge.

This means:

Parties can, and often do, resolve factual disputes about statelessness by stipulation or in a factual proffer; but
The court must independently determine, as a matter of law, whether those facts satisfy the statutory definition of a vessel “subject to the jurisdiction of the United States.”

4. Application to Jimenez‑Flores

The panel applied this framework to Jimenez‑Flores’s case and found:

The vessel had no indicia of nationality: no flag, no registration paperwork, and no nationality markings.
No one on board claimed to be the master or captain when the Coast Guard inquired.
No claim of nationality was made at all, despite questioning.

These were not contested issues of fact: Jimenez‑Flores explicitly admitted them in:

His written factual proffer; and
The Presentence Investigation Report (to which he did not object on these points).

Under Nunez and related cases, such admitted facts were sufficient to support a legal conclusion that the vessel was stateless. The Coast Guard was not required to follow any particular script in its questioning, and once no master or nationality claim surfaced, it had no duty to probe further.

The court therefore held that the MDLEA’s jurisdictional requirement was satisfied and rejected the subject‑matter jurisdiction challenge.

D. Due Process and the Absence of a U.S. Nexus

1. The nexus argument

Bautista‑Feliciano and Jimenez‑Flores argued that because:

They are foreign nationals;
The offenses occurred entirely on the high seas (within a foreign EEZ) with no territorial connection to the United States; and
The drugs were not shown to be destined for the United States,

application of the MDLEA violated due process. In many areas of extraterritorial criminal law, courts require some nexus between the defendant’s conduct and the United States to satisfy fairness concerns under the Due Process Clause.

2. Eleventh Circuit’s MDLEA line: no nexus required

The Eleventh Circuit, however, has consistently rejected a nexus requirement in MDLEA prosecutions involving the high seas. The panel cites several decisions:

United States v. Campbell, 743 F.3d 802 (11th Cir. 2014) – Held that the MDLEA’s extraterritorial reach is supported by the “universal” and “protective” principles of international law, and that a nexus to the United States is not required to satisfy due process.
United States v. Cabezas‑Montano – Rejected an as‑applied Felonies Clause challenge and due process claim regarding an MDLEA prosecution on the high seas without a U.S. nexus. The court reiterated that a nexus is not necessary when prosecuting drug trafficking on stateless vessels or vessels properly subject to U.S. jurisdiction.
United States v. Canario‑Vilomar, 128 F.4th 1374 (11th Cir. 2025) – An appellant conceded that the Eleventh Circuit had repeatedly rejected the nexus argument, but asked the court to revisit it. The panel refused, holding that prior decisions are binding and again emphasizing that “the conduct proscribed by the MDLEA need not have a nexus to the United States.”

The underlying rationale is that large‑scale maritime drug trafficking is universally condemned and understood to threaten the security and public order of many nations. Under the “universal” and “protective” principles of international law:

States may exercise jurisdiction over certain offenses deemed inherently of international concern (universal principle); and
States may criminalize and prosecute conduct outside their territory when it threatens vital national interests (protective principle).

The Eleventh Circuit treats the MDLEA as comfortably within these principles, such that due process is satisfied without a specific U.S. nexus.

3. As‑applied due process challenges foreclosed

Given this judicial background, the panel in Jimenez‑Flores found that:

Facial and as‑applied challenges to the MDLEA based on lack of nexus are foreclosed by binding precedent; and
Applying the MDLEA to foreign nationals on a stateless vessel in a foreign EEZ, with no demonstrated U.S. destination, does not violate due process within the Eleventh Circuit’s framework.

Thus, the due process arguments were rejected without extended analysis, precisely because they had been “rejected many times before.”

E. The Prior‑Panel‑Precedent Rule and the Stability of MDLEA Doctrine

A notable feature of the opinion is its explicit invocation of the Eleventh Circuit’s prior‑panel‑precedent rule, as articulated in Canario‑Vilomar:

Once a panel of the Eleventh Circuit has decided an issue in a published opinion, that holding is binding on all later panels and district courts within the circuit.
The later panel may not overrule or depart from prior panel precedent; only the Eleventh Circuit sitting en banc or the U.S. Supreme Court can do so.
There is no exception merely because a later party offers a reason or argument that prior litigants did not emphasize (“no overlooked‑argument exception”).

In this case, the prior‑panel‑precedent rule:

Bound the panel to Alfonso and Canario‑Vilomar on the status of EEZs as “high seas” and on the independence of the Felonies Clause from international law constraints; and
Bound it to Campbell, Cabezas‑Montano, and Canario‑Vilomar on the absence of any due‑process nexus requirement under the MDLEA.

As a result, the decision underscores that these core MDLEA issues—Felonies Clause authority in EEZs, the definition of stateless vessels, and the lack of a nexus requirement—are now deeply entrenched in Eleventh Circuit law.

IV. Complex Concepts Simplified

1. Exclusive Economic Zone (EEZ)

Under the U.N. Convention on the Law of the Sea (UNCLOS), an EEZ is a maritime area extending up to 200 nautical miles from a coastal state’s baseline. Within its EEZ, a state has:

Sovereign rights to explore, exploit, conserve, and manage natural resources; and
Jurisdiction over certain economic and environmental matters.

The EEZ is not the same as territorial waters (typically up to 12 nautical miles), where the coastal state has full sovereignty akin to that over its land territory. Beyond the territorial sea, ships generally enjoy high‑seas freedoms such as navigation.

The Eleventh Circuit treats EEZ waters as part of the “high seas” for purposes of Congress’s Felonies Clause power.

2. High Seas

In international law, the “high seas” refers to all parts of the sea not included in a state’s internal waters, territorial sea, or archipelagic waters. They are a global commons, traditionally beyond any single nation’s sovereign control.

For constitutional purposes, the Eleventh Circuit has held that Congress’s authority to define and punish “felonies committed on the high seas” extends to conduct in a foreign state’s EEZ.

3. Stateless Vessel

A stateless vessel is one that:

Is not registered in any country;
Does not fly a national flag;
Has no valid registration documents; and/or
Fails to assert any nationality when asked by authorized officials.

Under the MDLEA, several specific scenarios create “vessels without nationality,” including failure of the master or any individual to claim nationality when asked by U.S. officers and absence of nationality paperwork or flag.

Stateless vessels are “international outlaws” in maritime law and are particularly vulnerable to enforcement by all states, which is one reason they are frequently used for illicit purposes such as drug smuggling.

4. Felonies Clause vs. Piracies and Offences Clauses

Article I, Section 8, Clause 10 contains three related but distinct powers:

Piracies Clause – To define and punish piracies (classic maritime piracy).
Felonies Clause – To define and punish felonies committed on the high seas (broader category of serious crimes at sea, including drug trafficking).
Offences Clause – To define and punish offenses against the law of nations (e.g., war crimes, certain human‑rights violations, if recognized by customary international law).

The Eleventh Circuit locates the MDLEA chiefly in the Felonies Clause, not the Offences Clause, and insists that that power is not limited by customary international law.

5. Universal and Protective Principles of International Law

Universal Jurisdiction – Certain crimes (such as piracy, genocide, some war crimes) are so serious and universally condemned that any state may prosecute them, regardless of where they occurred or the nationality of the perpetrators or victims.
Protective Principle – A state may assert jurisdiction over foreign conduct that occurs outside its territory but threatens its security, governmental functions, or other vital interests.

The Eleventh Circuit repeatedly invokes these principles to justify the MDLEA’s broad extraterritorial reach as consistent with due process, even where there is no traditional territorial or personal nexus to the United States.

6. Guilty Pleas: Unconditional vs. Conditional

Unconditional Guilty Plea – The defendant admits guilt without reserving any issues for appeal. This generally waives all non‑jurisdictional challenges to pre‑plea proceedings, including many constitutional claims.
Conditional Guilty Plea – With the government’s and court’s consent, a defendant may plead guilty while expressly reserving the right to appeal specific pre‑trial rulings (e.g., a suppression ruling). If he prevails on appeal, he may withdraw the plea.

In Jimenez‑Flores, the appellants’ guilty pleas were unconditional and therefore waived their pre‑plea complaints about delay and right to counsel.

7. Non‑Argument Calendar and Per Curiam, Unpublished Opinions

Non‑Argument Calendar – Cases decided on the briefs without oral argument, typically when the panel concludes that oral argument would not significantly aid the decisional process.
Per Curiam – An opinion issued in the name of the court rather than a specific judge, often used for relatively routine applications of settled law.
Unpublished/“Not for Publication” – In the Eleventh Circuit, unpublished opinions are not binding precedent, though they may be cited as persuasive authority. The binding law remains in the published cases the panel applies.

Here, the non‑argument, per curiam, unpublished status signals that the panel viewed the issues as governed by settled precedent rather than as raising new legal questions.

V. Likely Impact on Future Cases and MDLEA Practice

1. Reinforcement of MDLEA’s Broad Extraterritorial Scope

Although unpublished, the decision is another clear application of a now‑solid line of Eleventh Circuit cases affirming:

Congress’s authority to apply the MDLEA to conduct in foreign EEZs as “felonies on the high seas” under the Felonies Clause;
The validity of the MDLEA even when customary international law might draw lines differently; and
The absence of any requirement that the government show a specific U.S. nexus in MDLEA prosecutions involving stateless vessels or vessels in EEZs.

Future MDLEA defendants in the Eleventh Circuit face a steep uphill climb if they seek to challenge:

Felonies Clause authority in EEZs;
The constitutionality of the MDLEA’s extraterritorial reach; or
Due process based on lack of U.S. nexus.

2. Guidance on Establishing Statelessness

The case underscores that statelessness can be established through:

Evidence (or admissions) that the vessel had no flag, no paperwork, and no nationality markings; plus
Evidence (or admissions) that no one claimed to be the master or asserted any nationality when questioned.

It also confirms that:

The Coast Guard is not required to use talismanic language or follow a rigid script; and
Defense admissions in factual proffers and PSRs are powerful evidence that can effectively concede the statelessness issue.

Practitioners should be aware that stipulating to or admitting these facts will almost certainly lead the court to find MDLEA jurisdiction as a matter of law.

3. Strategic Implications for Defense Counsel

The opinion offers practical lessons for defense strategy in MDLEA cases:

Preserving issues: If counsel intends to challenge delay, right‑to‑counsel violations, or certain suppression issues, they must consider negotiating a conditional guilty plea. An unconditional plea will usually foreclose appellate review.
Challenging statelessness: Any viable challenge to statelessness should be developed factually before or at trial. Admitting in a factual proffer that no one claimed nationality and that no indicia of nationality existed will likely doom any later jurisdictional attack.
Realism about constitutional challenges: In the Eleventh Circuit, broad constitutional attacks on the MDLEA’s extraterritorial application are largely settled against defendants. Counsel may need to focus on more fact‑bound issues (e.g., reliability of Coast Guard testimony, scope of consent, quantity of drugs) rather than structural constitutional challenges.

4. Broader Doctrinal Stability

By closely following and reapplying Alfonso, Campbell, Cabezas‑Montano, and Canario‑Vilomar, this opinion contributes to a stable and predictable MDLEA jurisprudence in the Eleventh Circuit. Within this circuit:

EEZ = “high seas” for Felonies Clause purposes;
MDLEA jurisdiction over stateless vessels in those waters is routine;
No nexus to the United States is required for due process; and
MDLEA vessel jurisdiction is a question of law for the judge, often resolved on stipulated or admitted facts.

VI. Conclusion

United States v. Estupinan / Bautista‑Feliciano / Jimenez‑Flores does not chart new doctrinal territory, but it is an important illustration of how established Eleventh Circuit MDLEA precedent operates in practice.

The opinion:

Reaffirms that unconditional, valid guilty pleas broadly waive pre‑plea constitutional claims, including alleged delay in presentment and denial of counsel.
Applies and solidifies precedent holding that foreign EEZs are part of the “high seas” under the Felonies Clause and that Congress’s power to define MDLEA offenses is not constrained by customary international law.
Shows how statelessness can be established through admitted facts regarding the absence of flag, documents, and any claim of nationality, aligning with De La Cruz, De La Garza, Cabezas‑Montano, and Nunez.
Reiterates that due process does not require a U.S. nexus for MDLEA prosecutions of maritime drug trafficking on the high seas, including within EEZs.
Demonstrates the force of the Eleventh Circuit’s prior‑panel‑precedent rule in foreclosing re‑litigation of MDLEA constitutional challenges.

In the broader legal context, this decision is another step in entrenching a robust, extraterritorial MDLEA regime within the Eleventh Circuit—one that gives U.S. authorities wide latitude to prosecute maritime drug trafficking in international and EEZ waters, and leaves defendants with limited room to mount successful constitutional or jurisdictional challenges on appeal.