United States v. De los Santos
3:24-cr-00278
| D.P.R. | Jun 27, 2025Background
- Rigoberto de los Santos was indicted on four counts, including drug trafficking and bringing aliens into the U.S. via an unregistered vessel.
- The vessel was intercepted north-east of Aguadilla, Puerto Rico, displaying no nationality, with all occupants claiming Dominican nationality without proof.
- The U.S. Coast Guard recovered four bales thrown overboard containing 79 kg of cocaine, which tested positive for cocaine.
- The Dominican Republic officially denied the vessel's registry, making it stateless per U.S. law.
- Defendant moved to dismiss the indictment, challenging the constitutionality of the Maritime Drug Law Enforcement Act (MDLEA) and alleging a violation of his Sixth Amendment rights due to deportation of potential witnesses.
- The government opposed the motion, and the matter was referred for a report and recommendation.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Constitutionality of MDLEA | MDLEA valid under Define and Punish Clause; prior precedent upholds law | MDLEA exceeds Congress’s authority under Article I, Section 8, Clause 10; international law constrains U.S. | MDLEA is constitutional under precedent; motion denied |
| Jurisdiction over Stateless Vessel | Vessel was stateless under U.S. and international law | Vessel not stateless per international law; certification insufficient for jurisdiction | Dept. of State certification is conclusive; U.S. jurisdiction proper |
| Exculpatory Evidence (Sixth Amendment) | Deported passengers provided no material, favorable evidence | Deportation deprived defendant of witnesses who could offer exculpatory testimony | No material or exculpatory testimony shown; no Sixth Amendment violation |
| Sufficiency of Indictment | Indictment facially sufficient; proper notice given | Indictment defective/lacks specificity; should be dismissed | Indictment met requirements; motion denied |
Key Cases Cited
- United States v. Guerrier, 669 F.3d 1 (1st Cir. 2011) (facial validity of indictments and court's role at pretrial stage)
- United States v. Matos-Luchi, 627 F.3d 1 (1st Cir. 2010) (jurisdiction and statelessness under MDLEA)
- United States v. Romero, 32 F.3d 641 (1st Cir. 1994) (State Department denial sufficient for jurisdiction over stateless vessel)
- United States v. Cardales-Luna, 632 F.3d 731 (1st Cir. 2011) (conclusiveness of U.S. certifications in MDLEA cases)
- United States v. Valenzuela-Bernal, 458 U.S. 858 (1982) (standards for Sixth Amendment violations due to deported witnesses)
- United States v. Bresil, 767 F.3d 124 (1st Cir. 2014) (materiality of exculpatory evidence in criminal prosecutions)