United States v. Quintero: Eleventh Circuit Affirms MDLEA Jurisdiction in Exclusive Economic Zones and Upholds Broad Definition of “Vessel Without Nationality”

Introduction

The Eleventh Circuit’s unpublished decision in United States v. Daniel Quintero, No. 22-12846 (Aug. 12, 2025), is the Court’s latest word on the reach of the Maritime Drug Law Enforcement Act (“MDLEA”). Daniel Quintero, a Colombian national, was convicted in the Southern District of Florida of (1) conspiracy to possess with intent to distribute five kilograms or more of cocaine and (2) possession with intent to distribute the same, while on board a vessel “subject to the jurisdiction of the United States.” On appeal, Quintero attacked the indictment and verdict on constitutional and statutory grounds, chiefly contending that:

46 U.S.C. § 70502(d)(1)(C)’s definition of a “vessel without nationality” is facially unconstitutional because it diverges from customary international law; and
His seizure in Panama’s Exclusive Economic Zone (“EEZ”) placed him outside the “high seas,” rendering the MDLEA inapplicable.

Invoking the Eleventh Circuit’s fresh precedent (United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024) and United States v. Canario-Vilomar, 128 F.4th 1374 (11th Cir. 2025)), the Government moved for—and the Court granted—summary affirmance. The panel (Branch, Brasher, and Anderson, JJ.) held that Quintero’s challenges were foreclosed by binding precedent and that no substantial question existed warranting further briefing.

Summary of the Judgment

The Court summarily affirmed Quintero’s convictions, concluding:

Section 70502(d)(1)(C) is constitutionally valid; Congress may deem a vessel “without nationality” when the claimed flag state neither confirms nor denies registry.
The Felonies Clause (Art. I, § 8, cl. 10) empowers Congress to criminalise drug trafficking within foreign EEZs; such zones form part of the “high seas” for domestic constitutional purposes.
A verbal claim of nationality is sufficient to trigger § 70502(d)(1)(C); no separate “nexus” to the United States is required.
Given controlling authority, Quintero’s appeal presented no substantial legal question, justifying summary disposition.

Analysis

1. Precedents Cited and Their Influence

a. United States v. Alfonso (11th Cir. 2024)

Key Holding: The Felonies Clause is not limited by customary international law; an EEZ is part of the high seas for MDLEA purposes.
Influence: Provided the foundational constitutional analysis the Quintero panel relied on to reject the EEZ argument.

b. United States v. Canario-Vilomar (11th Cir. 2025)

Key Holding: Section 70502(d)(1)(C)’s definition of “vessel without nationality” poses no constitutional error, expanding Alfonso’s “no plain error” ruling to “no error.”
Influence: Foreclosed Quintero’s facial challenge to § 70502(d)(1)(C).

c. United States v. Gruezo (11th Cir. 2023)

Key Holding: The MDLEA uses “nationality” and “registry” interchangeably; rejecting registry equals rejecting nationality.
Influence: Defeated Quintero’s argument that a claim of nationality does not trigger § 70502(d)(1)(C).

d. United States v. Cabezas-Montano (11th Cir. 2020)

Key Holding: MDLEA prosecutions do not require a “nexus” to the United States.
Influence: Disposed of Quintero’s late-raised “nexus” argument.

e. Groendyke Transportation, Inc. v. Davis (5th Cir. 1969)

Key Holding: Summary disposition is proper where the outcome is clear as a matter of law.
Influence: Provided procedural authority for granting summary affirmance.

2. Legal Reasoning of the Court

The panel’s reasoning proceeds in four logical steps:

Binding Precedent Controls. Under the Eleventh Circuit’s prior-panel-precedent rule, Alfonso, Canario-Vilomar, Gruezo, and Cabezas-Montano are dispositive. A panel cannot revisit or narrow those holdings absent en banc or Supreme Court intervention.
Constitutional Authority Under the Felonies Clause. Relying on Alfonso, the Court re-affirmed that Congress’s power “to define and punish Felonies committed on the high Seas” is not cabined by evolving international norms. Because the EEZ lies beyond any nation’s territorial sea, it constitutes the “high seas” domestically.
Statutory Interpretation of § 70502(d)(1)(C). In light of Gruezo and the statutory text, the Court reiterated that a claim of nationality or registry—verbal or written—invokes § 70502(d)(1)(C). If the putative flag state cannot “affirmatively and unequivocally” assert registry, the vessel is deemed stateless.
No Nexus Requirement. Following Cabezas-Montano, the MDLEA’s extraterritorial reach is complete upon proof that the vessel is “subject to the jurisdiction of the United States.” No additional link to U.S. territory or citizens is constitutionally mandated.

3. Potential Impact

Maritime Drug Enforcement: The decision further cements the Eleventh Circuit as the most government-friendly forum for maritime drug prosecutions, granting law-enforcement maximal jurisdictional latitude in the Caribbean and Eastern Pacific corridors.
Foreign Relations: By untethering statutory language from customary international law, the ruling may create friction with flag states whose vessels are treated as “stateless” absent confirmation—especially those lacking rapid registry-verification infrastructure.
Judicial Economy: The Court’s willingness to use summary affirmance signals that MDLEA jurisdictional challenges akin to Quintero’s will receive scant appellate sympathy, likely discouraging similar appeals.
Constitutional Interpretation: The opinion contributes to an emerging circuit split with courts (notably the Ninth Circuit) that afford greater weight to international law when construing extraterritorial statutes.

Complex Concepts Simplified

Exclusive Economic Zone (EEZ)

A band of ocean extending up to 200 nautical miles from a nation’s coastline. The coastal state enjoys sovereign rights to exploit natural resources but does not possess full sovereignty; international waters’ freedoms, including navigation, remain largely intact.

Vessel Without Nationality

Under § 70502(d)(1)(C) of the MDLEA, a boat is “without nationality” if its master claims a flag but the supposed flag state cannot definitively confirm or deny registration. This U.S. definition is broader than the one under customary international law but is valid domestically per Eleventh Circuit precedent.

Felonies Clause (U.S. Const. art. I, § 8, cl. 10)

Empowers Congress to “define and punish piracies and felonies committed on the high seas.” The Eleventh Circuit interprets this power expansively, unconstrained by modern international law.

Summary Affirmance

An appellate shortcut whereby the court affirms without full briefing because the result is clear as a matter of law, preserving judicial resources.

Conclusion

United States v. Quintero reinforces two pivotal propositions: (1) a foreign EEZ is constitutionally indistinguishable from the high seas for MDLEA enforcement, and (2) Congress may deem a vessel stateless when a claimed flag state declines or fails to confirm registration. By summarily affirming Quintero’s convictions, the Eleventh Circuit signaled that future defendants will find little traction in facial or as-applied attacks on § 70502(d)(1)(C) or in claims that EEZ seizures exceed congressional authority. Practitioners should focus instead on factual defenses—quantity, mens rea, or suppression—because jurisdictional challenges of this stripe are now effectively foreclosed in the Eleventh Circuit. In the broader legal landscape, Quintero exemplifies the Court’s commitment to a robust, text-centered reading of Congress’s Article I powers, even where that stance may exceed prevailing understandings of international law. Whether other circuits or the Supreme Court will endorse this trajectory remains a question for another day; for now, the Eleventh Circuit’s position could hardly be clearer.