United States v. Luis Munoz Miranda, 414 U.S. App. D.C. 305

Munoz Miranda and Valderrama Carvajal, Colombian nationals, were indicted under the Maritime Drug Law Enforcement Act (MDLEA) for participating in an international drug-smuggling conspiracy using stateless "go-fast" boats from Colombia (2006–2010).
Neither defendant left Colombia in furtherance of the conspiracy; both were arrested in Colombia, extradited to the U.S., and pleaded guilty without reserving appellate rights, submitting joint stipulated factual statements describing stateless vessels and specific shipments.
Before pleading, defendants moved to dismiss, arguing (a) the MDLEA is unconstitutional as applied (Article I High Seas power and Fifth Amendment nexus/due-process limits), (b) the conspiracy provision lacks extraterritorial reach, and (c) the charged vessels were not "subject to the jurisdiction of the United States." The district court denied dismissal and later accepted the guilty pleas.
Defendants then sought reconsideration; the district court again denied relief, concluding the vessels qualified as "without nationality" and thus fell within the MDLEA, and that the statute validly reached the charged conduct.
On appeal, the D.C. Circuit considered waiver from unconditional guilty pleas, whether certain claims implicate subject-matter jurisdiction (and so are unwaivable), and whether the stipulated facts supported the district court’s jurisdictional finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether defendants waived constitutional challenges by pleading guilty	Govt: unconditional pleas waive most challenges; only jurisdictional claims survive	Defs: as-applied Article I and due-process challenges are not waivable	Waived: both constitutional (Article I High Seas and Fifth Amendment nexus) claims were forfeited by unconditional pleas; not jurisdictional
Whether the MDLEA’s extraterritorial reach is a jurisdictional question	Govt: statute’s reach is merits, district court has jurisdiction to decide	Defs: extraterritorial application is jurisdictional and thus unwaivable	Held for Govt: extraterritoriality is a merits question, so waived by guilty pleas
Whether the MDLEA’s vessel-jurisdiction inquiry is subject-matter jurisdiction	Govt: term “jurisdiction” here is a legislative/jurisdictional element for merits	Defs: vessel-jurisdiction is a threshold jurisdictional requirement and thus unwaivable	Held for Defs: §70504(a) is jurisdictional—preliminary question for judge, immune from waiver
Whether the stipulated vessels were “subject to the jurisdiction of the United States” (i.e., stateless)	Govt: stipulations describe stateless vessels (no registry/flag) satisfying §70502(d)	Defs: vessels were in Colombian territorial waters when seized so cannot be stateless	Held for Govt: stipulations established the vessels were "without nationality"; situs at capture does not defeat stateless status under MDLEA

Bousley v. United States, 523 U.S. 614 (waiver of collateral attack after knowing, voluntary guilty plea)
Arbaugh v. Y & H Corp., 546 U.S. 500 (distinguishing jurisdictional conditions from merits elements)
United States v. Cotton, 535 U.S. 625 (defective indictment protection waivable)
Delgado-Garcia v. United States, 374 F.3d 1337 (D.C. Cir.) (as-applied due-process nexus claim waived by unconditional plea)
Blackledge v. Perry, 417 U.S. 21 (some constitutional rights cannot be waived when they bar being haled into court)
Menna v. New York, 423 U.S. 61 (double jeopardy/waiver limits on guilty pleas)
Morrison v. National Australia Bank Ltd., 561 U.S. 247 (extraterritoriality is a merits question)
Henderson ex rel. Henderson v. Shinseki, 562 U.S. 428 (requirement for readily administrable rule on jurisdictional labels)
Gonzalez v. United States, 311 F.3d 440 (1st Cir. view that MDLEA "jurisdiction" is non-jurisdictional)
De La Garza, 516 F.3d 1266 (11th Cir. treating MDLEA vessel requirement as jurisdictional)