United States v. Matos-Luchi
627 F.3d 1
| 1st Cir. | 2010Background
- MDLEA extends U.S. drug-law jurisdiction to vessels on the high seas, including stateless vessels; vessel status is a threshold issue affecting the statute’s reach.
- Coast Guard intercepted a small Dominican crewed yola off the Dominican Republic, seized cocaine packages from bales dropped at sea, and detained the three defendants after Dominican authorities took the vessel.
- Defendants were charged with MDLEA counts for possession with intent to distribute cocaine on board a vessel subject to U.S. jurisdiction; they moved to dismiss for lack of jurisdiction.
- District court held the yola was within U.S. jurisdiction under MDLEA and did not submit vessel-status to the jury; defendants were convicted by jury and sentenced to 235 months.
- Court’s central question: whether the government proved the yola was a vessel without nationality (stateless) under MDLEA, and whether vessel-status proof is by preponderance or beyond a reasonable doubt.
- Dissent would require genuine statelessness proof and reject the majority’s deeming approach; the dissent emphasizes international-law constraints and statutory text.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Standard of proof for vessel status under MDLEA | Government advocates preponderance standard | Lipez argues beyond-reasonable-doubt standard | Preponderance of the evidence |
| Whether the yola qualifies as a vessel without nationality under MDLEA | Yola is stateless under MDLEA (statelessness either genuine or deemed) | Dominican nationality or not stateless; insufficient proof | Yes, the yola falls within MDLEA’s stateless-vessel category |
| Whether questioning aboard the adjacent Dominican cutter suffices to trigger 70502(d)(1)(B) | Questioning aboard adjacent cutter can count as aboard the vessel | Aboard means on the vessel itself; not on the cutter | Majority: it qualifies; dissenting view questions textual scope |
Key Cases Cited
- United States v. Rosero, 42 F.3d 166 (3d Cir.1994) (stateless-vessel jurisprudence under MDLEA; implied broad incorporation of stateless concepts)
- United States v. González, 311 F.3d 440 (1st Cir.2002) (vessel-status as a non-elemental, threshold issue; aids jurisdictional analysis)
- Lauritzen v. Larsen, 345 U.S. 571 (U.S. 1953) (nationality of ships; customary international law governs vessel nationality)
- United States v. Victoria, 876 F.2d 1009 (1st Cir.1989) (stateless vessel concept and enforcement on the high seas)