United States v. Matthaios Fafalios, 817 F.3d 155

Fafalios, a 65-year-old Greek citizen, was chief engineer aboard the Marshall Islands-flagged M/V Trident Navigator.
He was responsible for oil record book entries documenting bilge-water discharges.
In December 2013, he ordered untreated bilge water pumped overboard in international waters and did not record it.
The ship later reached New Orleans; a whistleblower alerted Coast Guard, leading to an investigation.
He was indicted for failing to maintain an oil record book, obstruction of justice, and witness tampering; convicted on all counts after trial; he moved for Rule 29 acquittal focused on §1908(a) element (master) and the district court reserved ruling.
The court reverses, vacates, and remands for entry of a judgment of acquittal under §1908(a).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the master requirement is a element under §151.25 for liability.	Fafalios contends he was not master, so no liability.	Government argues regulation imposes duty to maintain regardless of master status.	Yes, only master or person in charge bears maintenance duty; acquittal proper.

Lara v. Cinemark USA, Inc., 207 F.3d 783 (5th Cir. 2000) (regulation meaning is plain when unambiguous)
Anthony v. United States, 520 F.3d 374 (5th Cir. 2008) (regulation should be construed by plain meaning)
Copeland v. Comm’r, 290 F.3d 326 (5th Cir. 2002) (same-words-in-act meaning rule cited)
Jho v. United States, 534 F.3d 398 (5th Cir. 2008) (unrecorded discharge outside U.S. waters not alone liability; aiding/abetting theory discussed)
BFP v. Resolution Trust Corp., 511 U.S. 531 (1994) (textual interpretation supports semantic consistency in regulations)
United States v. Cooper, 135 F.3d 960 (5th Cir. 1998) (identical words in different parts of act have same meaning)