United States v. Simon Herrera Maliano, 22-11155

Luis Mendez and Simon Maliano were apprehended off the coast of Colombia transporting nearly 300 kilograms of cocaine by speedboat.
The speedboat had no visible nationality markers; Mendez claimed Colombian nationality, but Colombia did not confirm or deny this.
As a result, under 46 U.S.C. § 70502(d)(1)(C), the vessel was classified as “without nationality,” bringing it under U.S. jurisdiction via the Maritime Drug Law Enforcement Act (MDLEA).
Both defendants pleaded guilty to conspiracy to possess with intent to distribute cocaine, in exchange for dropping other charges.
Before sentencing, Mendez (and later Maliano) moved to dismiss, arguing the Act unconstitutionally extended U.S. jurisdiction beyond international law.
The district court denied their motions and sentenced Mendez to 132 months, Maliano to 82 months; both appealed on the jurisdiction issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of MDLEA jurisdiction over vessels "without nationality" not recognized as stateless under international law	Mendez: Congress exceeded its authority by defining “vessel without nationality” beyond international law; this unlawfully extends U.S. jurisdiction to foreigners on foreign vessels	United States: Congress’s constitutional authority allows it to define "stateless vessel" for the purposes of U.S. law regardless of international law	Court held that Congress’s definition in § 70502(d)(1)(C) is a constitutional exercise of its authority; international law does not limit this congressional power

United States v. Canario-Vilomar, 128 F.4th 1374 (11th Cir. 2025) (held that international law does not restrict Congress’s ability to define “stateless vessels” in the MDLEA)
United States v. Alfonso, 104 F.4th 815 (11th Cir. 2024) (affirmed Congress’s constitutional power to punish felonies on the high seas is not limited by customary international law)