United States v. Bautista‑Feliciano: Guilty Plea Waivers and MDLEA Jurisdiction over Stateless Vessels in Foreign EEZs

I. Introduction

The Eleventh Circuit’s unpublished per curiam decision in United States v. Estupinan / Bautista‑Feliciano / Jimenez‑Flores (docket nos. 23‑12067, 23‑12114, 23‑12137) reaffirms and consolidates several important strands of federal criminal and constitutional law:

• The sweeping waiver effect of an unconditional guilty plea on pre‑plea constitutional challenges, including alleged violations of prompt presentment and the right to counsel.
• The broad extraterritorial reach of the Maritime Drug Law Enforcement Act (MDLEA), particularly its application to stateless vessels operating in a foreign nation’s Exclusive Economic Zone (EEZ).
• The Eleventh Circuit’s settled position that the MDLEA does not require any nexus to the United States to satisfy due process.
• The evidentiary threshold for treating a vessel as a “vessel without nationality” under the MDLEA.

The case arises from the interdiction of a vessel carrying cocaine in the Dominican Republic’s EEZ. All three defendants— Jose Hugo Estupinan, Ramon Gabriel Bautista‑Feliciano, and Alcibiades Jimenez‑Flores—were convicted of:

• Conspiracy to possess with intent to distribute cocaine while on board a vessel subject to U.S. jurisdiction, and
• Possession with intent to distribute cocaine while on board such a vessel,

all under the MDLEA, 46 U.S.C. §§ 70503, 70506.

On appeal, the defendants raised five principal challenges:

1. Delay / prompt presentment (Bautista‑Feliciano): The indictment should be dismissed because the government delayed presenting him to a magistrate judge and delayed obtaining a criminal complaint.
2. Sixth Amendment right to counsel (Estupinan): The indictment should be dismissed because he was allegedly denied counsel at a critical stage of the proceedings.
3. Constitutional and statutory authority for MDLEA jurisdiction: All three defendants argued that the government lacked authority to prosecute them under the MDLEA because their conduct occurred in the Dominican Republic’s EEZ, rather than on the “high seas.”
4. Statelessness / subject‑matter jurisdiction (Jimenez‑Flores): The district court lacked jurisdiction because the government allegedly failed to prove that the vessel was “without nationality.”
5. Due process / lack of nexus (Bautista‑Feliciano and Jimenez‑Flores): Their convictions violated due process because the offenses bore no connection to the United States.

The Eleventh Circuit rejected all of these arguments and affirmed the convictions, relying heavily on its existing MDLEA jurisprudence and its strict prior‑panel‑precedent rule. While the decision does not formally create a new doctrinal rule, it is significant for how clearly it cements three propositions in Eleventh Circuit law:

• Unconditional guilty pleas foreclose almost all pre‑plea constitutional challenges, including even serious structural claims.
• The MDLEA reaches stateless vessels in foreign EEZs under the Felonies Clause, with no international law or nexus limitation.
• Relatively minimal, undisputed facts (no flag, no papers, no master identified, no claim of nationality) are sufficient to deem a vessel stateless for MDLEA jurisdictional purposes.

II. Summary of the Opinion

A. Standards of Review and Prior‑Panel‑Precedent Rule

The court first lays out the applicable standards:

• Denial of a motion to dismiss an indictment is reviewed for abuse of discretion (citing United States v. Gayden and United States v. Lyons).
• Constitutional, jurisdictional, and statutory interpretation questions are reviewed de novo (citing United States v. Alfonso).

The court also emphasizes the Eleventh Circuit’s strict prior‑panel‑precedent rule (citing United States v. Canario‑Vilomar): a panel is bound by previous panel holdings unless those holdings are overruled by the Supreme Court or by the Eleventh Circuit sitting en banc. The court expressly rejects any notion of an “overlooked argument” exception to this rule.

B. Waiver of Pre‑Plea Constitutional Claims by Guilty Plea

For Bautista‑Feliciano and Estupinan, the panel holds that their unconditional, valid guilty pleas:

• Waived any challenge based on delay in presentment and obtaining a complaint.
• Waived any Sixth Amendment challenge based on the alleged denial of counsel at a critical stage.

Citing Class v. United States, United States v. De La Garza, United States v. Pierre, United States v. Castillo, and United States v. Williams, the court reiterates that:

• A valid guilty plea renders irrelevant—and unappealable—non‑jurisdictional, case‑specific constitutional challenges arising before the plea.
• Only an attack on the voluntariness or knowing nature of the plea survives.
• Even structural errors can be waived by plea.

Because neither Bautista‑Feliciano nor Estupinan challenge the validity of their guilty pleas or claim that they entered conditional pleas preserving specific issues, their pre‑plea claims are deemed waived without reaching the merits.

C. MDLEA Jurisdiction and Conduct in a Foreign EEZ

All three defendants argued that their conduct occurred in the Dominican Republic’s Exclusive Economic Zone, and thus could not be treated as occurring on the “high seas” for purposes of Congress’s authority under Article I, § 8, cl. 10 (the Piracies and Felonies Clause).

The court:

• Recites the MDLEA’s framework, including its coverage of vessels without nationality (46 U.S.C. § 70502(c), (d), (e)).
• Notes that the MDLEA expressly applies extraterritorially, even outside U.S. territorial waters (46 U.S.C. § 70503(b)).
• Relies heavily on earlier decisions—especially United States v. Alfonso and United States v. Canario‑Vilomar—to reaffirm that:
  • An EEZ is part of the “high seas” for purposes of Congress’s Felonies Clause power.
  • International law does not limit Congress’s power under the Felonies Clause in enacting and applying the MDLEA.
  • MDLEA enforcement in EEZs is constitutionally valid.

Therefore, the argument that MDLEA prosecutions in a foreign EEZ exceed congressional authority is foreclosed by binding precedent, and the panel summarily rejects it.

D. Stateless Vessel / Subject‑Matter Jurisdiction

Defendant Jimenez‑Flores argued that the district court lacked subject‑matter jurisdiction because the government failed to prove that the vessel was “without nationality” within the meaning of the MDLEA.

The panel:

• Reminds that under the MDLEA, whether a vessel is “subject to the jurisdiction of the United States” is a jury‑free jurisdictional question of law for the judge, not an element of the offense (citing 46 U.S.C. § 70504(a) and United States v. Iguaran).
• Explains that while parties may stipulate to facts relevant to jurisdiction, they cannot stipulate directly to the legal conclusion of jurisdiction itself.
• Draws on United States v. Nunez, United States v. De La Cruz, United States v. De La Garza, and United States v. Cabezas‑Montano to show how statelessness can be established.

Applying these principles, the court emphasizes that Jimenez‑Flores himself admitted, in both his factual proffer and Presentence Investigation Report, that:

• The vessel had no indicia of nationality—no flag, no registration papers, and no visible markings of nationality.
• None of the men on board claimed to be the master or captain of the vessel.
• No claim of nationality was made by anyone.

Under Nunez, these facts:

• Relieve the Coast Guard of any duty to conduct further inquiry into nationality; and
• Are sufficient to support the conclusion that the vessel is a “vessel without nationality” for MDLEA purposes.

The court therefore holds that the government adequately established statelessness and, concomitantly, that the district court possessed subject‑matter jurisdiction.

E. Due Process and Nexus to the United States

Finally, Bautista‑Feliciano and Jimenez‑Flores argued that due process was violated because their conduct bore no nexus to the United States.

The Eleventh Circuit rejects this argument as repeatedly foreclosed by binding precedent:

• United States v. Campbell and United States v. Canario‑Vilomar hold that the MDLEA’s reach is justified by the universal and protective principles of jurisdiction, and that it does not require a U.S. nexus.
• United States v. Cabezas‑Montano likewise rejects as‑applied constitutional challenges for MDLEA prosecutions arising on the high seas without a U.S. nexus.

Accordingly, the court concludes that:

• The MDLEA is a constitutional exercise of congressional power under the Felonies Clause, even as applied to foreign nationals on the high seas (including EEZs) with no demonstrable connection to the United States.
• No due process violation occurs merely because defendants are foreign nationals apprehended outside U.S. territory without a U.S. nexus.

The court therefore affirms on all issues.

III. Detailed Analysis

A. Procedural Background and Framing of the Issues

While the opinion does not provide extensive factual narrative, the procedural posture is clear:

• All three appellants were prosecuted under the MDLEA for cocaine trafficking aboard a vessel intercepted by the U.S. Coast Guard in the Dominican Republic’s EEZ.
• All three were convicted in the Southern District of Florida.
• Bautista‑Feliciano and Estupinan entered unconditional guilty pleas; they did not attack the validity of their pleas on appeal.
• Each raised distinct challenges to the indictment and jurisdiction, some constitutional and some statutory.

The Eleventh Circuit’s analytical structure tracks the logical order of potential dispositive issues:

1. Whether the guilty pleas themselves waive certain claims (if so, those claims are extinguished).
2. Whether the district court properly exercised jurisdiction under the MDLEA (both constitutional and statutory dimensions).
3. Whether MDLEA’s application here is consistent with due process.

This structure matters: by resolving waiver first, the court underscores that many seemingly serious constitutional issues disappear once a valid, unconditional guilty plea is entered.

B. Precedents Cited and Their Influence

1. Guilty Pleas and Waiver of Constitutional Claims

• Class v. United States, 583 U.S. 174 (2018)
  Class held that a guilty plea does not bar a defendant from pursuing a facial constitutional challenge to the statute of conviction itself. The Eleventh Circuit here invokes Class for a related but distinct proposition: that a guilty plea does bar case‑specific challenges to government conduct preceding the plea. Thus, while structural attacks on the statute may survive, fact‑bound challenges like delayed presentment or denial of counsel at a particular stage are waived.
• United States v. De La Garza, 516 F.3d 1266 (11th Cir. 2008)
  De La Garza articulates the Eleventh Circuit’s rule that an unconditional, knowing, and voluntary guilty plea waives all non‑jurisdictional defects in the proceedings. This is the core doctrinal basis for the court’s conclusion that Bautista‑Feliciano and Estupinan cannot challenge pre‑plea errors.
• United States v. Pierre, 120 F.3d 1153 (11th Cir. 1997)
  Pierre is cited both for the general guilty‑plea waiver principle and specifically for holding that a valid plea also waives a Sixth Amendment speedy trial claim. The panel analogizes Estupinan’s alleged denial of counsel at a critical stage to other Sixth Amendment pre‑plea issues that are extinguished by a plea.
• United States v. Castillo, 899 F.3d 1208 (11th Cir. 2018)
  Castillo confirms that a defendant who does not dispute the validity of his guilty plea “cannot complain about the specific facts of his detention.” This supports the court’s refusal to entertain Bautista‑Feliciano’s delay‑in‑presentment claim.
• United States v. Williams, 29 F.4th 1306 (11th Cir. 2022)
  Williams clarifies that a guilty plea can even waive claims of structural error, which are otherwise among the most serious constitutional defects. By invoking Williams, the panel underscores the breadth of the waiver doctrine: the mere fact that an alleged defect would typically demand reversal does not preclude waiver by plea.

Together, these cases allowed the court to dispose of potentially weighty constitutional allegations without any factual inquiry: once the plea stands, those claims simply cannot be heard.

2. MDLEA Jurisdiction, Stateless Vessels, and EEZs

• United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024)
  Alfonso is central. There, the Eleventh Circuit upheld the MDLEA’s application to a vessel seized in the Dominican Republic’s EEZ. The court held:
  • The MDLEA is a valid exercise of Congress’s power under the Felonies Clause (“to define and punish Piracies and Felonies committed on the high Seas”).
  • International law does not limit Congress’s Felonies Clause power.
  • For constitutional purposes, an EEZ is part of the “high seas”.
  In the present case, the defendants make essentially the same arguments rejected in Alfonso, and the panel deems itself bound by that prior decision.
• United States v. Canario‑Vilomar, 128 F.4th 1374 (11th Cir. 2025)
  Canario‑Vilomar reaffirmed Alfonso in the context of vessels interdicted in the EEZs of Panama and Colombia. It held that:
  • Congress is not constrained by international law when defining “stateless vessel” or the boundaries of the “high seas” under the MDLEA.
  • A defendant cannot evade MDLEA jurisdiction merely by operating in a foreign EEZ rather than in more distant high seas.
  In this case, the court cites Canario‑Vilomar both for its substantive holdings on MDLEA jurisdiction and for its strong statement of the prior‑panel‑precedent rule, rejecting any “overlooked arguments” exception.
• United States v. Nunez, 1 F.4th 976 (11th Cir. 2021)
  Nunez is a key stateless‑vessel case. There, the vessel:
  • Carried no registry papers,
  • Bore no markings of nationality, and
  • No one (master or crew) made any claim of nationality.
  The court held this sufficient to deem the vessel stateless. Crucially, Nunez also emphasized:
  • There are no fixed international law requirements regarding what questions must be asked to determine a vessel’s nationality.
  • Authorities typically conduct some form of examination, but where there is no master and no indicia of nationality, the vessel may fairly be treated as stateless.
  In the present case, the panel directly applies this reasoning: because no one identified a master and no one claimed nationality, further Coast Guard inquiry was unnecessary; the admitted facts sufficed to establish statelessness.
• United States v. De La Cruz, 443 F.3d 830 (11th Cir. 2006)
  De La Cruz involved a vessel flying no flag, carrying no registration papers, and having no nationality markings, with a captain hiding among the crew and no one claiming nationality. The court deemed it stateless under 46 U.S.C. § 70502(d)(1)(B). This case supplies a factual template for statelessness that mirrors the facts here.
• United States v. De La Garza, 516 F.3d 1266 (11th Cir. 2008) (MDLEA context)
  Apart from its guilty‑plea waiver holding, De La Garza also involved statelessness under the MDLEA, where the defendant stipulated that the vessel had no flag and no indicia of nationality. This dual use—both for waiver and statelessness—makes De La Garza particularly relevant.
• United States v. Cabezas‑Montano, 949 F.3d 567 (11th Cir. 2020)
  Cabezas‑Montano held a vessel stateless when Coast Guard personnel:
  • Asked the crew to identify the master and no one did, and
  • Asked if anyone wished to claim nationality and no one responded.
  The court expressly held that the specific phrasing of the Coast Guard’s questions is not critical, as long as the individual in charge has an opportunity to claim nationality. This supports the proposition that a lack of any claim suffices to establish statelessness.
• United States v. Iguaran, 821 F.3d 1335 (11th Cir. 2016)
  Iguaran clarifies that MDLEA jurisdictional questions (such as whether a vessel is “subject to the jurisdiction of the United States”) are:
  • Questions of law for the judge, not the jury, and
  • Preliminary factual questions and legal determinations reviewed de novo.
  This frames the court’s treatment of Jimenez‑Flores’s jurisdictional challenge as a purely legal matter.

3. Due Process, Nexus, and Extraterritorial Application

• United States v. Campbell, 743 F.3d 802 (11th Cir. 2014)
  Campbell is an early and foundational case on MDLEA due process. It concludes that MDLEA prosecutions do not require a U.S. nexus because:
  • Drug trafficking on the high seas threatens U.S. interests and global stability,
  • The MDLEA is supported by the protective principle (protecting national security and governmental functions) and the universality principle (international consensus about the heinousness of certain offenses).
• United States v. Canario‑Vilomar, 128 F.4th 1374 (11th Cir. 2025)
  In addition to its Felonies Clause holding, Canario‑Vilomar reaffirmed that:
  • MDLEA prosecutions need not have a nexus to the United States to satisfy due process.
  • Arguments to the contrary are squarely foreclosed by prior precedent including Campbell.
• United States v. Cabezas‑Montano, 949 F.3d 567 (11th Cir. 2020)
  The court in Cabezas‑Montano also rejected as‑applied challenges to the MDLEA under the Felonies Clause and due process, even where the vessel and crew have no nexus to the United States beyond interdiction on the high seas.

These cases jointly lock in the Eleventh Circuit’s view that the MDLEA may constitutionally reach foreign nationals on stateless vessels in international waters (including EEZs) even absent a U.S. nexus.

C. The Court’s Legal Reasoning

1. Guilty Pleas as a Barrier to Pre‑Plea Constitutional Claims

The panel’s handling of Bautista‑Feliciano and Estupinan’s arguments illustrates the strong doctrinal line between:

• Structural attacks on the statute itself, which may survive a guilty plea; and
• Fact‑bound or procedural attacks on the prosecution, which are usually waived by a voluntary and knowing plea.

Here, the alleged constitutional defects—delay in presentment and denial of counsel at a critical pre‑plea stage—fall into the second category. The court does not inquire into:

• How long the defendants were detained before presentment,
• What communications with counsel occurred (or failed to occur), or
• Whether any specific prejudice flowed from the alleged delay.

Instead, it applies a bright‑line rule: because the pleas were:

• Valid (knowing and voluntary), and
• Unconditional (no reservation of issues under Rule 11(a)(2)),

the defendants waived “all non‑jurisdictional challenges to the constitutionality of the conviction” and of the pre‑plea proceedings. This reinforces a powerful procedural message:

Defendants who wish to preserve claims such as delayed presentment or denial of counsel must either go to trial or enter a conditional plea explicitly preserving those issues.

2. MDLEA Jurisdiction in a Foreign EEZ

The defendants sought to exploit the geographical nuance of an Exclusive Economic Zone, suggesting that conduct within a foreign EEZ is not “on the high seas” for purposes of the Felonies Clause and that Congress’s authority under Article I, § 8, cl. 10 does not extend so far.

The court responds in two related ways:

1. Constitutional interpretation:
   Relying on Alfonso and Canario‑Vilomar, the panel reiterates that a foreign EEZ forms part of the “high seas” for constitutional purposes. The Felonies Clause power is not confined to waters beyond 200 nautical miles or outside all national claims; it is broad enough to cover at least EEZs, where the coastal state enjoys limited economic rights but not full sovereignty.
2. Rejection of international law limits on the Felonies Clause:
   The panel endorses the prior holdings that international law does not limit Congress’s Felonies Clause power in enacting and applying the MDLEA. While international law concepts may inform statutory interpretation in some contexts, they do not circumscribe constitutionally granted power in this domain.

This dual reasoning leads to a categorical conclusion: MDLEA enforcement in foreign EEZs is constitutionally proper. Under the prior‑panel‑precedent rule, the defendants’ arguments—no matter how refined—cannot alter that result short of en banc or Supreme Court intervention.

3. Establishing Statelessness and Jurisdiction

The statutory framework is central to this issue:

• 46 U.S.C. § 70502(c)(1)(A) defines a “vessel subject to the jurisdiction of the United States” to include a “vessel without nationality.”
• § 70502(d)(1)(B), (D) give specific (but non‑exhaustive) examples of when a vessel is “without nationality,” including:
  • When the master or individual in charge fails, upon request, to make a claim of nationality; and
  • When no one claims to be the master, no one is identified as the individual in charge, and the vessel otherwise lacks any claim of nationality or registry.
• § 70502(e) explains what constitutes a “claim of nationality or registry” (e.g., presenting registration documents, flying a national flag).

The court’s reasoning hinges on three critical factual admissions by Jimenez‑Flores:

1. The vessel had no indicia of nationality (no flag, no papers, no markings).
2. No one claimed to be the master or captain.
3. No one made any claim of nationality for the vessel.

Under Nunez and related cases, these facts are sufficient—indeed, paradigmatic—of a stateless vessel. The court also emphasizes that under international law there is no magic formula of questions to ask; what matters is that:

• The authorities give those on board a reasonable opportunity to claim nationality, and
• No such claim is made, and no objective indicia of nationality are present.

In effect, the court reasons that:

If a vessel carries no papers, flies no flag, bears no nationality markings, and no one aboard claims to be the master or to assert a nationality, the vessel may be treated as stateless under both U.S. law and customary international law.

Because MDLEA jurisdiction is a preliminary legal question for the judge, these undisputed factual admissions easily allow the court to affirm jurisdiction without a jury finding.

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

The due process arguments challenge the fairness of applying U.S. criminal law to foreign nationals on a foreign‑adjacent portion of the ocean (a foreign EEZ), where:

• The drugs were not destined (at least demonstrably) for the United States, and
• The defendants had no apparent links to the United States.

The court’s response is brief but decisive, resting entirely on existing MDLEA jurisprudence:

• The Eleventh Circuit has “explained repeatedly” that MDLEA prosecutions require no nexus to the United States.
• The justifications for this are rooted in:
  • The universal jurisdiction principle—drug trafficking on the high seas is widely condemned and of international concern; and
  • The protective principle—the United States has a sovereign interest in preventing transnational drug trafficking that threatens its security and domestic order.

By aligning these principles with the Felonies Clause, the court reaffirms that Congress can—and did—legitimately choose to criminalize certain maritime drug activities worldwide, independent of specific U.S. effects or connections in a particular case.

D. Impact on Future Cases and the Relevant Area of Law

1. Cementing MDLEA Jurisdiction in Foreign EEZs

This decision, in combination with Alfonso and Canario‑Vilomar, effectively closes off constitutional challenges to MDLEA jurisdiction in EEZs within the Eleventh Circuit. Litigants can no longer plausibly argue that:

• EEZs are outside the “high seas” for Felonies Clause purposes, or
• International law limitations on enforcement in an EEZ restrict Congress’s Felonies Clause power.

Unless and until the Supreme Court or the Eleventh Circuit en banc revisits this area, drug interdictions in any foreign EEZ within Eleventh Circuit waters are squarely within MDLEA reach, at least where vessels are stateless or otherwise fall within § 70502(c).

2. Strengthening the Stateless‑Vessel Doctrine

The court’s reliance on factual admissions in the factual proffer and Presentence Investigation Report reinforces practical aspects of MDLEA litigation:

• Prosecutors can frequently establish statelessness through stipulated or undisputed facts about the vessel’s appearance and the crew’s statements.
• Defendants who admit:
  • No flag,
  • No papers,
  • No master, and
  • No claim of nationality,
  will find it very difficult to mount a viable jurisdictional challenge later.
• Courts are not expecting elaborate rituals or specific phrasing from the Coast Guard. As long as those aboard had an opportunity to claim nationality and did not do so, an inference of statelessness will typically follow.

This makes MDLEA jurisdiction over stateless vessels both broad and relatively simple to prove.

3. Clarifying the Scope of Guilty Plea Waivers

On the domestic criminal procedure side, the opinion underscores that:

• Unconditional guilty pleas will foreclose almost all pre‑plea constitutional challenges, including:
  • Claims of delayed presentment,
  • Alleged denial of counsel at critical stages,
  • Speedy trial violations, and
  • Even some structural errors.
• Defense counsel must be strategic if there is a desire to litigate such claims on appeal, whether by:
  • Going to trial, or
  • Negotiating a conditional plea that explicitly preserves identified issues under Federal Rule of Criminal Procedure 11(a)(2).

For MDLEA practitioners in particular, this opinion is a reminder that pre‑plea motions challenging Coast Guard conduct or pre‑indictment proceedings will often be effectively nullified by a subsequent unconditional plea.

4. Locking In the No‑Nexus Rule

By affirming that no U.S. nexus is required for MDLEA prosecutions, the Eleventh Circuit continues to adopt one of the most expansive views of extraterritorial criminal jurisdiction among federal circuits. The consequence is that:

• Foreign nationals apprehended on stateless vessels (or vessels otherwise subject to MDLEA jurisdiction) anywhere on the high seas or in foreign EEZs may be brought to U.S. courts without demonstrating that their conduct was aimed at the United States.
• Future defendants seeking to argue that due process requires a nexus will find themselves squarely foreclosed by binding precedent unless they can distinguish their cases on some novel ground (which seems unlikely, given the breadth of prior decisions).

This has significant implications for international maritime enforcement and for diplomatic relations, although those policy questions lie beyond the four corners of the opinion.

E. Complex Concepts Simplified

1. The Maritime Drug Law Enforcement Act (MDLEA)

The MDLEA (46 U.S.C. §§ 70501–70508) is a federal statute that:

• Makes it a crime to possess with intent to distribute controlled substances, or to conspire to do so, on board certain vessels.
• Applies to:
  • U.S. vessels,
  • Certain foreign vessels with flag‑state consent, and
  • Vessels without nationality (stateless vessels).
• Expressly applies even outside the territorial jurisdiction of the United States (i.e., extraterritorially).

2. “Vessel Without Nationality”

A stateless vessel is a ship that:

• Is not properly registered in any country, and
• Does not fly a national flag or carry registration documents, or
• Is denied nationality by a state it purports to belong to, or
• Otherwise fails to make any credible claim of nationality when questioned by competent authorities.

Under 46 U.S.C. § 70502(d), this includes situations where:

• The master or person in charge fails to claim nationality upon request, or
• No one aboard claims to be the master and no one claims nationality, and there is no documentation or flag.

In practical terms, if the Coast Guard finds a boat on the high seas with:

• No flag,
• No registration papers,
• No markings of nationality, and
• No one willing to say “this is a [country] vessel,”

that boat can be treated as stateless and thus subject to MDLEA jurisdiction.

3. Exclusive Economic Zone (EEZ)

An Exclusive Economic Zone is a maritime zone extending up to 200 nautical miles from a coastal state’s shoreline. Under international law (e.g., the U.N. Convention on the Law of the Sea), a coastal state has:

• Special rights to exploit and manage natural resources in its EEZ (fish, oil, etc.), but
• Does not enjoy full sovereignty over the waters, unlike its territorial sea (typically up to 12 nautical miles).

For purposes of the U.S. Constitution’s Felonies Clause, the Eleventh Circuit has held that EEZs are part of the “high seas”, meaning Congress’s power to define and punish felonies “on the high seas” extends into foreign EEZs.

4. Prior‑Panel‑Precedent Rule

The Eleventh Circuit’s prior‑panel‑precedent rule means:

• Once a panel of the Eleventh Circuit decides a legal issue and publishes that decision,
• All later panels are bound by that holding,
• Unless:
  • The Supreme Court clearly overrules it, or
  • The Eleventh Circuit en banc overrules it.

Importantly, the court here explicitly rejects any exception based on “overlooked” arguments or authorities. Even if a later panel thinks an earlier panel missed a key point, it must still follow the earlier case.

5. Universal and Protective Principles of Jurisdiction

In international law:

• The universal principle allows any state to exercise jurisdiction over certain offenses considered crimes against all (e.g., piracy, slavery, genocide, and, in the Eleventh Circuit’s view, some forms of maritime drug trafficking).
• The protective principle allows a state to punish conduct outside its territory that threatens its security or governmental functions.

The Eleventh Circuit uses these principles to justify the MDLEA’s broad extraterritorial scope, even without a particularized nexus to the United States.

IV. Conclusion

This unpublished per curiam decision in United States v. Bautista‑Feliciano (and co‑appellants) is nonetheless an important consolidating opinion in Eleventh Circuit MDLEA jurisprudence.

Key takeaways include:

• Guilty plea waivers: An unconditional, knowing, and voluntary guilty plea waives virtually all pre‑plea constitutional challenges, including delayed presentment and denial of counsel at a critical stage. Only challenges to the validity of the plea itself or to the constitutionality of the statute on its face remain viable.
• MDLEA and EEZs: The Eleventh Circuit firmly treats foreign EEZs as part of the “high seas” for Felonies Clause purposes. MDLEA prosecutions in such zones are constitutionally sound, and international law does not limit Congress’s power here.
• Stateless vessels: A vessel with no flag, no papers, no markings, no identified master, and no claim of nationality can be treated as “without nationality” under the MDLEA. Admissions to these facts in plea documents or PSRs will normally suffice to establish jurisdiction.
• No nexus requirement: Due process does not require a nexus between the defendant’s conduct and the United States in MDLEA prosecutions. The statute’s reach is justified by universal and protective principles and by Congress’s Felonies Clause authority.
• Binding effect of precedent: The court reiterates the rigidity of its prior‑panel‑precedent rule, making clear that panels cannot revisit earlier MDLEA holdings merely because new arguments or perspectives are raised.

In the broader legal context, this opinion confirms that within the Eleventh Circuit, the MDLEA remains a robust and far‑reaching tool for U.S. maritime drug enforcement. Challenges premised on EEZ geography, lack of U.S. nexus, or nuanced international law arguments are effectively foreclosed at the panel level. At the same time, the decision underscores the critical strategic importance of plea decisions: in MDLEA cases, as in many others, the choice to plead guilty—especially without conditions—may irrevocably close the door on a range of potentially significant constitutional claims.