United States v. Walther Quijije
22-11845
11th Cir.Mar 11, 2025Background
- Segundo Bravo Lopez and Walther Vera Quijije were convicted for drug offenses involving cocaine distribution and possession on a vessel under U.S. jurisdiction.
- Both defendants argued the district court lacked jurisdiction due to alleged constitutional infirmities in the Maritime Drug Law Enforcement Act (MDLEA).
- They contended that the Act’s definition of "vessel without nationality" exceeded Congress’s power and conflicted with international law.
- They also challenged the Act for lacking a required nexus to the United States and for potential due process violations.
- Bravo Lopez, specifically, appealed the substantive reasonableness of his 168-month sentence, arguing the court overemphasized the drug quantity and underappreciated his personal circumstances.
Issues
| Issue | Bravo Lopez & Vera Quijije's Argument | Government's Argument | Held |
|---|---|---|---|
| Constitutionality under Felonies Clause | The MDLEA exceeds Congress’s power by defining "vessel without nationality" contrary to international law. | The Act is consistent with the Felonies Clause. | For government; prior precedent rejects this constitutional challenge. |
| U.S. Nexus Requirement | MDLEA is unconstitutional for lacking a nexus between the offense and the U.S., violating due process. | No nexus is required; protective and universal principles support MDLEA's reach. | For government; no nexus or due process violation under precedent. |
| Substantive Reasonableness of Sentence | District court abused discretion by overly focusing on drug quantity, not considering personal hardships. | Sentence within guidelines; court considered all relevant factors, including mitigation. | Sentence affirmed; no abuse of discretion. |
Key Cases Cited
- United States v. Campbell, 743 F.3d 802 (11th Cir. 2014) (no U.S. nexus required for MDLEA offenses due to universal and protective jurisdiction principles)
- United States v. Cabezas-Montano, 949 F.3d 567 (11th Cir. 2020) (rejected due process challenges to MDLEA’s lack of U.S. nexus)
- United States v. Rendon, 354 F.3d 1320 (11th Cir. 2003) (recurring rejection of due process challenges to MDLEA in the Eleventh Circuit)
- Gall v. United States, 552 U.S. 38 (2007) (established abuse-of-discretion framework for reviewing sentences)
- United States v. Irey, 612 F.3d 1160 (11th Cir. 2010) (sentence vacatur requires a clear error in judgment under § 3553(a)).