United States v. Diaz-Doncel
811 F.3d 517
| 1st Cir. | 2016Background
- In June 2013 U.S. Coast Guard personnel (aboard a cutter and a Dutch warship) interdicted a cigarette boat in the Caribbean, arrested the crew and seized the vessel; Diaz was among those arrested.
- A federal grand jury indicted Diaz on three counts: two under the Maritime Drug Law Enforcement Act (MDLEA) for conspiracy to possess and aiding and abetting possession of cocaine on a vessel, and one count of aiding and abetting failure to heave.
- Diaz filed a late pretrial motion arguing Congress exceeded its Article I powers in enacting the MDLEA; the district court denied the motion as untimely, treating it as not implicating subject-matter jurisdiction.
- On the second day of trial Diaz entered an unconditional (straight) guilty plea to all three counts and was sentenced to concurrent terms (168 months on each MDLEA count; 60 months for failure to heave).
- On appeal Diaz argued his MDLEA convictions must be reversed because the statute exceeds Congress’s Article I powers; the government and majority held he waived that claim by pleading guilty.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a straight guilty plea preserves an Article I challenge to the MDLEA | Diaz argued the MDLEA is unconstitutional under Article I and this claim can be raised despite a guilty plea | Government argued an unconditional guilty plea waives all non-jurisdictional claims including Article I challenges to the statute | Court held Diaz waived the Article I challenge by pleading guilty; plea forfeits this claim |
| Whether an Article I challenge to the MDLEA is a challenge to the court's subject-matter jurisdiction | Diaz contended the claim implicates subject-matter jurisdiction and thus survives a guilty plea | Government maintained the challenge is a statutory/constitutional defense, not a jurisdictional defect of the district court | Court followed precedent that an Article I challenge to MDLEA is not a district-court subject-matter jurisdiction claim; exception to waiver does not apply |
| Whether Blackledge/Menna exceptions preserve constitutional claims after a guilty plea | Diaz did not invoke Blackledge/Menna; no argument that his case involves vindictive prosecution or double jeopardy | Government noted Blackledge/Menna are narrow and inapplicable | Court noted those exceptions do not apply; recent authority agrees they do not cover this challenge |
| Applicability of recent circuit authority (e.g., Miranda) to bar plea challenges | Diaz sought to press the constitutional argument on the merits despite plea | Government relied on circuit and D.C. Circuit authority affirming waiver after guilty plea | Court relied on precedent including Miranda, Cardales-Luna, Nueci-Peña to affirm waiver and affirm convictions |
Key Cases Cited
- United States v. González, 311 F.3d 440 (1st Cir. 2002) (guilty plea ordinarily forfeits objections; limited exceptions discussed)
- United States v. Cardales-Luna, 632 F.3d 731 (1st Cir. 2011) (Article I challenge to MDLEA treated as non-jurisdictional; dissenting opinion argued otherwise)
- United States v. Nueci-Peña, 711 F.3d 191 (1st Cir. 2013) (reiterating that Article I challenges to MDLEA are not district-court subject-matter jurisdiction defects)
- United States v. Miranda, 780 F.3d 1185 (D.C. Cir. 2015) (guilty plea bars defendant from asserting Article I challenge to MDLEA on appeal)
- Blackledge v. Perry, 417 U.S. 21 (1974) (narrow exception to plea waiver for vindictive prosecution/due process contexts)
- Menna v. New York, 423 U.S. 61 (1975) (double jeopardy plea-based exception to waiver)