Three defendants, Tony Rafael Henriquez, Jose Antonio Acosta-Pinedo, and Julio Javier Liriano-Mercado, appealed their convictions for conspiracy and possession with intent to distribute cocaine. The charges stemmed from an interdiction operation on a vessel in the ocean near Colombia. The defendants argued that the U.S. lacked jurisdiction because the offense occurred within Colombia's Exclusive Economic Zone rather than on the high seas, that the vessel was not stateless, that the Netherlands' involvement in the enforcement action stripped U.S. courts of authority, and that the statute violated due process by being vague and failing to provide specific warnings or a nexus to the United States.
The court addressed four primary arguments. First, regarding the location of the offense, the court adhered to its precedent in United States v. Alfonso, holding that the term 'high seas' in the Felonies Clause includes a country's Exclusive Economic Zone. Therefore, Congress has the power to criminalize drug trafficking in these zones. Second, concerning statutory jurisdiction, the court found that the vessel was stateless. Under 46 U.S.C. § 70502(d)(1)(B), a vessel is subject to U.S. jurisdiction if the master fails to make a claim of nationality upon request. The record showed that when Coast Guard officers boarded, the master identified himself but remained silent when asked about the vessel's nationality. Third, the court rejected the argument that the Netherlands' involvement defeated jurisdiction. The record established that U.S. Coast Guard officers assumed tactical control and carried out the boarding, making the foreign partnership unremarkable and legally insufficient to strip jurisdiction. Finally, the court dismissed due process challenges. It held that the MDLEA is not void for vagueness, citing United States v. Gruezo, which found the statute sufficiently clear. The court also ruled that the lack of 'reverse Miranda' warnings was waived by the defendants' guilty pleas and that a nexus to the United States is not required for MDLEA prosecutions due to universal and protective principles.
The defendants' convictions and sentences remain in effect. The ruling clarifies that U.S. jurisdiction extends to drug trafficking in foreign Exclusive Economic Zones and that a failure to claim nationality upon boarding is sufficient to establish a vessel as stateless. It also confirms that international cooperation in maritime interdictions does not limit U.S. prosecutorial authority under the MDLEA.