MDLEA Reaffirmed: EEZ Treated as “High Seas,” Statelessness Defined by Statute, No U.S. Nexus Required, and “Nationality” Equals “Registry”

Case: United States v. Jose Marin (consolidated with United States v. Rodolfo Rodriguez Vazquez and United States v. Stanley Javier Cabrera)
Court: U.S. Court of Appeals for the Eleventh Circuit (Per Curiam, Non-Argument Calendar)
Date: 2025-12-29
Key Statutes: 46 U.S.C. §§ 70503(a)(1), 70506(b), 70502(d)(1)(C); 21 U.S.C. § 960(b)(1)(B); U.S.S.G. § 3B1.2(b)

1. Introduction

These consolidated appeals arose from a Coast Guard interdiction roughly 111 miles off the Dominican Republic in international waters. Three defendants—Rodolfo Rodriguez Vazquez, Jose Manuel Leon Marin (identified as the vessel’s master), and Stanley Javier Cabrera—were found aboard a vessel with no indicia of nationality carrying 23 bales of cocaine (575 kilograms). Leon-Marin claimed Venezuelan nationality for the vessel; Venezuela “could neither confirm nor deny” the claim. The Coast Guard therefore treated the vessel as “without nationality” under the Maritime Drug Law Enforcement Act (MDLEA), 46 U.S.C. § 70502(d)(1)(C), and the defendants were prosecuted in the Southern District of Florida.

The defendants pleaded guilty to conspiracy to possess with intent to distribute five or more kilograms of cocaine on the high seas (with the possession count dismissed). On appeal, they renewed broad constitutional and jurisdictional attacks on the MDLEA, and two defendants (Vazquez and Cabrera) additionally challenged the denial of a mitigating-role reduction under U.S.S.G. § 3B1.2(b).

Central issues:

Whether the MDLEA exceeds Congress’s power under the Felonies Clause when applied in an Exclusive Economic Zone (EEZ).
Whether Congress may define “vessel without nationality” more broadly than customary international law.
Whether due process requires a “nexus” between the offense and the United States for MDLEA prosecutions.
Whether “claim of nationality” (as made here) differs from a “claim of registry” so as to defeat MDLEA jurisdiction.
Whether ocean-going couriers transporting a large cocaine load qualify as “minor participants.”

2. Summary of the Opinion

The Eleventh Circuit affirmed all convictions and rejected each challenge largely on stare decisis grounds. The panel held that existing circuit precedent foreclosed: (i) the argument that an EEZ is outside the “high seas” for Felonies Clause purposes; (ii) the argument that customary international law limits Congress’s ability to define “stateless vessel” under the MDLEA; (iii) the argument that due process requires a U.S. nexus; and (iv) the argument that a claim of “nationality” is legally insufficient because the statute requires a claim of “registry.”

The court also held that the district court did not clearly err in denying Vazquez and Cabrera a minor-role reduction, emphasizing their critical function in transporting a very large quantity of cocaine and their substantial expected compensation.

3. Analysis

3.1 Precedents Cited

The opinion is primarily a reaffirmation-and-application decision: it does not innovate doctrinally so much as it consolidates and re-applies recent MDLEA precedents to a familiar set of defense challenges.

United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024), cert. denied, 145 S. Ct. 2706 (2025)
Influence: Alfonso is decisive on the defendants’ “EEZ is not the high seas” theory. Citing Alfonso, the panel reiterates that a nation’s exclusive economic zone “is part of the ‘high seas’ for purposes of the Felonies Clause[.]” This forecloses the attempt to carve EEZ conduct outside Congress’s Article I authority.
United States v. Canario-Vilomar, 128 F.4th 1374, 1381 (11th Cir.), cert. denied, No. 25-5506 (U.S. Oct. 6, 2025)
Influence: Canario-Vilomar supplies the controlling answer to the claim that customary international law constrains Congress’s statutory definition of statelessness. The panel repeats Canario-Vilomar’s core proposition that the Felonies Clause is “not limited by customary international law,” and therefore “international law cannot limit Congress’s authority to define ‘stateless vessel’ for purposes of the [Act].” This is pivotal because the MDLEA’s jurisdiction in this case turned on 46 U.S.C. § 70502(d)(1)(C), which treats a vessel as “without nationality” when the claimed nation cannot confirm or deny nationality.
United States v. Cabezas-Montano, 949 F.3d 567 (11th Cir. 2020)
Influence: Cabezas-Montano provides two key pillars. First, it anchors the standard of review for jurisdiction, constitutionality, and role reductions. Second—and more substantively—it supports the proposition that the MDLEA is valid under the Felonies Clause even without a U.S. nexus, a point the panel treats as already resolved in the circuit.
United States v. Campbell, 743 F.3d 802, 809-10 (11th Cir. 2014) (cited via Cabezas-Montano)
Influence: Campbell is the foundational nexus case in the Eleventh Circuit’s MDLEA line. By citing Campbell through Cabezas-Montano, the panel treats the “no nexus” rule as settled: due process does not require proof that the defendants’ maritime drug trafficking bore a domestic U.S. connection.
United States v. Gruezo, 66 F.4th 1284 (11th Cir.), cert. denied, 144 S. Ct. 178 (2023)
Influence: Gruezo does double work. On jurisdiction, it forecloses the semantic challenge distinguishing “nationality” from “registry,” holding the MDLEA “treats the terms ‘nationality’ and ‘registry’ as interchangeable throughout [section] 70502.” On sentencing, it is cited for the defendant’s burden to prove entitlement to a role reduction and as a comparator for denying minor-role status to essential maritime couriers.
United States v. Rodriguez De Varon, 175 F.3d 930 (11th Cir. 1999) (en banc)
Influence: De Varon supplies the governing framework for minor-role adjustments: (1) compare the defendant’s role to the relevant conduct attributed to him; (2) compare the defendant to other participants in that relevant conduct. The panel uses De Varon to validate focusing on what Vazquez and Cabrera actually did (transported a massive load) and to reject speculative comparisons to unknown or uncharged organizers.
United States v. Valois, 915 F.3d 717 (11th Cir. 2019)
Influence: Valois is invoked as part of a consistent line upholding denials of minor-role reductions to crew members/couriers performing “essential” transport functions in maritime drug cases.

3.2 Legal Reasoning

(a) MDLEA constitutionality and the Felonies Clause. The opinion’s constitutional analysis is driven by binding circuit precedent. The defendants advanced multiple Felonies Clause theories: that the EEZ is not the high seas; that the statutory statelessness rule conflicts with customary international law; and that the absence of a U.S. nexus renders the prosecution unconstitutional. The panel treats each theory as already decided in the government’s favor:

EEZ coverage: Under United States v. Alfonso, an EEZ counts as “high seas” for Felonies Clause purposes.
Customary international law limits: Under United States v. Canario-Vilomar, customary international law does not limit Congress’s Felonies Clause power to define statelessness for the MDLEA.
No nexus requirement: Under United States v. Cabezas-Montano and United States v. Campbell, the MDLEA may be applied without a U.S. nexus.

(b) Subject-matter jurisdiction under the MDLEA. The defendants tried to reframe the boarding as jurisdictionally defective by arguing that the master claimed only Venezuelan “nationality,” not “registry.” The panel again relies on precedent—United States v. Gruezo—that the MDLEA uses “nationality” and “registry” interchangeably in § 70502. Given Venezuela’s “neither confirm nor deny” response, § 70502(d)(1)(C) permitted treating the vessel as “without nationality,” making it a “vessel subject to the jurisdiction of the United States” for MDLEA purposes.

(c) Minor-role reduction. Applying United States v. Rodriguez De Varon and the Guideline commentary factors (U.S.S.G. § 3B1.2 cmt. n.3(C)), the court affirms the district court’s conclusion that Vazquez and Cabrera failed to prove they were “substantially less culpable.” Key facts emphasized:

They knowingly transported an extraordinarily large quantity of cocaine (575 kg).
Their transportation role was “critical” to the offense conduct for which they were held accountable.
They stood to receive substantial compensation (one million Dominican pesos each, per the PSRs).

The panel treats these as hallmarks of “essential” participants and cites Gruezo, Cabezas-Montano, and United States v. Valois to reinforce that denial of the reduction is not clear error on such facts.

3.3 Impact

Although designated “NOT FOR PUBLICATION,” the decision is significant as a practical signal of how firmly the Eleventh Circuit’s MDLEA architecture is now settled. The opinion illustrates a consolidated rule-set that district courts and litigants can expect to govern most MDLEA interdiction cases in this circuit:

Geography: EEZ-based challenges are effectively dead on arrival under United States v. Alfonso.
Statelessness: Arguments that § 70502(d)(1)(C) conflicts with customary international law are foreclosed under United States v. Canario-Vilomar.
Nexus: Due process “nexus” attacks are foreclosed under United States v. Cabezas-Montano and United States v. Campbell.
Jurisdictional semantics: Attempts to distinguish “nationality” from “registry” are foreclosed under United States v. Gruezo.
Sentencing: In maritime cocaine transport cases, large quantities plus essential transport duties plus meaningful payment will continue to weigh heavily against minor-role reductions, particularly where the defendant’s comparison to more culpable actors is speculative or not tied to the “relevant conduct” of conviction under United States v. Rodriguez De Varon.

The combined effect is to push MDLEA litigation away from broad facial/as-applied constitutional attacks (at least in the Eleventh Circuit) and toward narrower, record-specific disputes (e.g., the adequacy of nationality inquiries, evidentiary sufficiency on vessel status, and individualized sentencing fact-finding).

4. Complex Concepts Simplified

MDLEA (Maritime Drug Law Enforcement Act): A federal statute making it a U.S. crime to traffic drugs on certain vessels on the high seas, including “vessels without nationality,” even when the conduct is far from U.S. shores.
Felonies Clause (U.S. CONST. art. I, § 8, cl. 10): The Constitution’s grant of power to Congress to “define and punish” felonies on the high seas. In this circuit’s MDLEA jurisprudence, it is the primary constitutional hook for extraterritorial maritime drug prosecutions.
Exclusive Economic Zone (EEZ): A maritime zone extending up to 200 nautical miles from a coastal state where the coastal state has certain resource-related rights. The defendants argued an EEZ is not the “high seas.” The Eleventh Circuit (via United States v. Alfonso) treats the EEZ as part of the “high seas” for Felonies Clause purposes.
“Vessel without nationality” under 46 U.S.C. § 70502(d)(1)(C): Includes a vessel for which a claimed nation of nationality does not “affirmatively and unequivocally” confirm the claim (here, Venezuela could neither confirm nor deny). That statutory status is what triggers U.S. jurisdiction under the MDLEA.
“Nexus” requirement: Some extraterritorial crimes require a link to the United States to satisfy due process. In the Eleventh Circuit’s MDLEA cases, a nexus is not required for high-seas drug trafficking.
Minor-role reduction (U.S.S.G. § 3B1.2(b)): A sentencing reduction for defendants who are “substantially less culpable” than average participants. Under United States v. Rodriguez De Varon, courts focus on (1) what the defendant was held accountable for, and (2) how the defendant compares to others involved in that same relevant conduct.

5. Conclusion

This decision affirms three MDLEA conspiracy convictions and reinforces, through direct application of binding precedent, four settled propositions in the Eleventh Circuit: (1) an EEZ is treated as “high seas” for Felonies Clause purposes; (2) customary international law does not constrain Congress’s statutory definition of statelessness in § 70502(d)(1)(C); (3) MDLEA prosecutions do not require a U.S. nexus; and (4) “nationality” and “registry” are interchangeable for MDLEA nationality-claim analysis. On sentencing, the opinion underscores that maritime couriers entrusted with massive quantities of cocaine and promised substantial payment will rarely qualify as “minor participants,” absent concrete, record-based proof of substantially lesser culpability under United States v. Rodriguez De Varon.