United States v. Walkin De Leon Peralta
699 F. App'x 918
| 11th Cir. | 2017Background
- Defendant Walkin De Leon Peralta appealed convictions under the Maritime Drug Law Enforcement Act (MDLEA) for possession with intent to distribute and conspiracy involving a vessel subject to U.S. jurisdiction.
- MDLEA criminalizes manufacturing, distributing, or possessing with intent to distribute controlled substances on a U.S. vessel or a vessel subject to U.S. jurisdiction.
- The statute defines a vessel “subject to the jurisdiction of the United States” to include vessels without nationality, including those whose claimed registry is denied.
- A 1996 MDLEA amendment provides that U.S. jurisdiction over a vessel is not an element of the offense and that jurisdictional questions are preliminary legal issues for the judge.
- De Leon argued the MDLEA is unconstitutional as applied to offenses lacking a nexus to the United States, raising due process and jury-trial (Fifth and Sixth Amendment) objections.
- The Eleventh Circuit affirmed, applying binding precedent that rejects De Leon’s challenges and upholds the MDLEA as constitutional as applied.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Scope of Congress’s Felonies Clause power under MDLEA | MDLEA cannot reach drug trafficking on the high seas absent a nexus to the U.S. | Congress may punish felonies on the high seas under the Felonies Clause; MDLEA valid without a U.S. nexus | MDLEA is a valid exercise of congressional power as applied; no nexus required |
| Due process/personal jurisdiction | It violates due process to prosecute defendants without a nexus to the U.S. | Due process is satisfied; statute applies without nexus | Conviction does not violate Fifth Amendment due process even without U.S. nexus |
| Jury fact-finding (Fifth and Sixth Amendments) | Jury must determine factual existence of extraterritorial jurisdiction | Jurisdictional element is not required to be submitted to a jury under MDLEA amendment | Fifth and Sixth Amendments do not require the jury to decide jurisdictional facts under MDLEA |
| Procedural rule of precedent | N/A (De Leon preserved arguments) | Prior Eleventh Circuit precedent controls disposition | Court affirms based on binding precedent; arguments preserved for further review |
Key Cases Cited
- United States v. Estupinan, 453 F.3d 1336 (11th Cir.) (MDLEA enacted to punish drug trafficking on the high seas)
- United States v. Campbell, 743 F.3d 802 (11th Cir.) (upheld MDLEA absent U.S. nexus; addressed due process and jury issues)
- United States v. Cruickshank, 837 F.3d 1182 (11th Cir.) (reaffirmed Campbell’s conclusions on MDLEA constitutionality)
- United States v. Rendon, 354 F.3d 1320 (11th Cir.) (prior affirmation of MDLEA application and constitutionality)
- United States v. Tinoco, 304 F.3d 1088 (11th Cir.) (addressed MDLEA jurisdictional and constitutional questions)
- United States v. Vega-Castillo, 540 F.3d 1235 (11th Cir.) (explains binding-effect of prior precedent rule)