United States v. Danfi Gonzalez Iguaran
2016 U.S. App. LEXIS 8692
| 11th Cir. | 2016Background
- Iguaran pleaded guilty to conspiring to distribute cocaine aboard a vessel under the MDLEA, 46 U.S.C. §§ 70503(a)(1), 70506(b).
- On appeal he argued for the first time that the district court lacked subject-matter jurisdiction because the record did not show the vessel was subject to U.S. jurisdiction.
- The MDLEA treats certain vessels (including "vessels without nationality") as subject to U.S. jurisdiction; a vessel is "without nationality" if those aboard fail, on request, to claim nationality or registry.
- The district court made no express factual findings on jurisdiction; Iguaran’s plea agreement said he was on a vessel "subject to the jurisdiction of the United States," but did not recite underlying facts (e.g., failure to claim nationality).
- The panel held that jurisdictional questions are reviewed de novo and that parties cannot stipulate jurisdiction; the record here lacked necessary facts to establish jurisdiction.
- The Court vacated the judgment and remanded for a limited evidentiary proceeding so the government may prove—and Iguaran may dispute—whether the vessel was subject to U.S. jurisdiction; if proven, conviction reinstated, if not, charge dismissed for lack of jurisdiction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of review for unraised jurisdictional objection | Government: plain-error review because Iguaran did not object below | Iguaran: jurisdictional defects are not forfeitable; review de novo | Court: de novo review of jurisdictional question; factual findings reviewed for clear error |
| Whether plea agreement admits jurisdictional facts | Government: plea language admitting the vessel was "subject to the jurisdiction" constitutes admission | Iguaran: plea does not admit factual predicate (e.g., failure to claim nationality) | Court: parties may not stipulate jurisdiction; the plea did not supply facts establishing jurisdiction |
| Whether factual record supports MDLEA jurisdiction | Government: other coconspirator’s plea included facts (no claim of nationality) supporting jurisdiction | Iguaran: only record in his case matters; no such facts in his record | Court: record in Iguaran’s case lacks necessary jurisdictional facts |
| Appropriate remedy for inadequate record on jurisdiction | Government: (implicitly) proceed on existing record | Iguaran: (implicitly) challenge jurisdiction | Court: vacate judgment and remand for limited proceedings to develop jurisdictional facts; reinstate conviction only if government proves jurisdiction |
Key Cases Cited
- McCoy v. United States, 266 F.3d 1245 (11th Cir.) (jurisdictional errors not subject to plain- or harmless-error analysis)
- United States v. Giraldo-Prado, 150 F.3d 1328 (11th Cir.) (subject-matter jurisdiction may be raised for first time on appeal)
- Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (Sup. Ct.) (subject-matter jurisdiction may be raised at any time)
- United States v. Cotton, 535 U.S. 625 (Sup. Ct.) (defects in subject-matter jurisdiction require correction regardless of party forfeiture)
- United States v. Tinoco, 304 F.3d 1088 (11th Cir.) (clear-error review of district court factfindings relevant to jurisdiction)
- United States v. De La Garza, 516 F.3d 1266 (11th Cir.) (MDLEA’s "vessel subject to the jurisdiction" is a jurisdictional prerequisite)
- United States v. Betancourth, 554 F.3d 1329 (11th Cir.) (same)
- W. Peninsular Title Co. v. Palm Beach Cty., 41 F.3d 1490 (11th Cir.) (parties may not stipulate federal jurisdiction)
- Travaglio v. Am. Express Co., 735 F.3d 1266 (11th Cir.) (same)
- Bush v. United States, 703 F.2d 491 (11th Cir.) (stipulation to jurisdiction does not vest subject-matter authority)
- Eng’g Contractors Ass’n of S. Fla. v. Metro. Dade Cty., 122 F.3d 895 (11th Cir.) (parties may stipulate facts bearing on jurisdiction)
- Williams v. Best Buy Co., 269 F.3d 1316 (11th Cir.) (remand appropriate when record underdeveloped on jurisdictional facts)
- Belleri v. United States, 712 F.3d 543 (11th Cir.) (remand when serious question exists regarding factual predicate for jurisdiction)
- Rolling Greens MHP, LP v. Comcast SCH Holdings LLC, 374 F.3d 1020 (11th Cir.) (remand for limited purpose to determine jurisdiction)