Maritime Drug Law Enforcement Act

MDLEA

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Category: Felonies Clause

11th Circuit Affirms MDLEA Convictions in U.S. v. Jimenez Marin Upholding Jurisdiction Under Felonies Clause

Posted on Jun 25Jun 25 by Sean Gajewski

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)….

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Florida Court Rules that MDLEA Can Snare Drug Traffickers Who Never Set Sail

Posted on Feb 21 by Sean Gajewski

On 24 October 2024, Middle District of Florida’s Judge Kathryn Kimball Mizelle held that Congress may punish maritime drug trafficking conspirators even if they are never on the high seas in U.S. v. Montero-Monsavlo, No. 8:21-CR-377-KKM-AEP, 2024 WL 4534222 (M.D. Fla. Oct. 21, 2024). On 27 August 2019, CG LEDET aboard a Dutch vessel encountered…

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Unpacking the First Circuit’s Ruling in United States v. Dávila-Reyes: MDLEA Challenges, International Law, and Constitutional Considerations

Posted on Jan 3 by Sean Gajewski

Apologies for the hiatus, MDLEA fans! Life’s been a whirlwind lately with work commitments, the holidays, and other adventures keeping me on my toes. But here I am, back and ready to dive into a few MDLEA cases. Also, happy new year to all of you—may it bring joy, success, and countless opportunities your way!…

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Judge Besosa in the District of Puerto Rico issues two decisions concerning the Constitutionality of the MDLEA

Posted on Aug 24Aug 24 by Sean Gajewski

Judge Besosa in the District of Puerto Rico issued two recent decisions that address, among other things,  arguments against the Constitutionality of the MDLEA: (1) U.S. v. Hernandez-Gamboa, No. CR 21-323 (FAB), 2023 WL 5199393 (D.P.R. Aug. 14, 2023); and (2) U.S. v. Martinez-Felipe, et al., No. CR 20-359 (FAB), 2023 WL 5290124 (D.P.R. Aug….

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Second Circuit rules that the MDLEA does not require a nexus for stateless vessels and that Congress did not exceed its authority under Article I of the Constitution in enacting the MDLEA

Posted on Jul 16Jul 18 by Sean Gajewski

It’s been about four months since we’ve seen a circuit court decision concerning the MDLEA. Well, the wait is over. The Second Circuit recently had to address the Constitutionality of prosecuting co-conspirators for their land-based activities under the Maritime Drug Law Enforcement Act (MDLEA) in United States v. Antonius, No. 21-1083, 2023 WL 4410951 (2d…

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Recent Blog Posts

  • 11th Circuit Affirms MDLEA Convictions in U.S. v. Jimenez Marin Upholding Jurisdiction Under Felonies Clause
  • The 5th Circuit Weighs in on Determining Jurisdiction Before Change of Plea
  • Florida Court Rules that MDLEA Can Snare Drug Traffickers Who Never Set Sail
  • Supreme Court Denies Davila-Reyes Defendants’ Petition
  • District of Puerto Rico Addresses Jurisdiction for a Third Time in U.S. v. Thomas Chalwell

Latest Decisions

  • United States v. Velez-Acosta, No. 22-13528, 2024 WL 806537 (11th Cir. Feb. 27, 2024)
  • U.S. v. Osvaldo Gonzalez, No. 22-cr-20350-ALTMAN, 2023 WL 4580901 (S.D.Fla. July 18, 2023)
  • U.S. v. Barbosa-Rodriguez, — F.Supp.3d —-, 2023 WL 4230143 (D.P.R. June 28, 2023)
  • U.S. v. Mariani-Romero, et al., No. 22-313 (FAB), 2022 WL 20184569 (D.P.R. June 22, 2023)
  • U.S. v. Iona-Dejesus, No. 22-20473-CR, 2023 WL 3980082 (S.D. Fla. May 4, 2023)

Disclaimer

This blog is written by an attorney employed by the U.S. Government. However, all views expressed on this website are mine and should not be construed as the views of the U.S. Government, including the U.S. Coast Guard.

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