Well, we finally got an MDLEA case to summarize! Unfortunately, it’s probably one of the shortest decisions from the 11th Circuit that I’ve seen. But since we haven’t had a post in a while, I’ll summarize it anyway. The case is U.S. v. Jimenez Marin, No. 24-10445, 2025 WL 1740834 (11th Cir. June 24, 2025).
In U.S. v. Jimenez Marin, the defendant appealed his convictions for conspiracy and possession with intent to distribute marijuana aboard a vessel subject to U.S. jurisdiction. The defendant argued, like many MDLEA defendants, that the federal government lacked authority to prosecute felonies committed on the high seas under the MDLEA, especially since the interdiction occurred in another foreign nation’s exclusive economic zone (EEZ). Despite acknowledging that his argument was foreclosed by existing precedent, the defendant sought further review to preserve his objection to jurisdiction. The 11th Circuit affirmed his convictions, citing the MDLEA’s applicability to vessels without nationality and its enforcement beyond U.S. territorial waters. The court referenced United States v. Alfonso, which upheld the MDLEA’s validity under Congress’s power to define and punish felonies on the high seas, including within EEZs:
“We repeatedly have upheld the MDLEA as a valid exercise of Congress’s power ‘to define and punish … Felonies on the high Seas.’” Alfonso, 104 F.4th at 820 (quoting United States v. Estupinan, 453 F.3d 1336, 1338–39 (11th Cir. 2006)). In Alfonso, the defendants appealed their convictions under the MDLEA, which arose from an incident where the United States Coast Guard seized a vessel in the Dominican Republic’s EEZ. Id. at 818–20. The defendants argued, in relevant part, that the district court lacked subject matter jurisdiction because the EEZ was not part of the “high seas.” Id. We held that “international law does not limit the Felonies Clause.” Id. at 826. We further held that a nation’s EEZ is “part of the ‘high seas’ for purposes of the Felonies Clause in Article I of the Constitution,” and thus, “enforcement of the MDLEA in EEZs is proper.” Id. at 823, 827.”
Jimenez Marin, No. 24-10445, 2025 WL 1740834, at *1. As a result of this binding precedent, the defendant’s argument that the court lacked subject matter jurisdiction was rejected.
Take-away: It appears that the 11th Circuit does not wish to address jurisdictional challenges to the MDLEA and is adhering to current precedent, waiting to see if the Supreme Court will weigh in on the matter. Notably, the Supreme Court decided not to grant certiorari in the Dávila-Reyes case. Therefore, for now, at least in the 11th Circuit, subject matter jurisdiction is obtained through the Felonies Clause in Article I of the Constitution.