USA v. Canario-Vilomar, No. 22-12077 (11th Cir. 2025)
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Two defendants, Antonio Lemus and Carlos Daniel Canario-Vilomar, were convicted of cocaine-related charges under the Maritime Drug Law Enforcement Act (MDLEA). Lemus was apprehended on December 30, 2021, when U.S. Coast Guard officers intercepted a vessel north of Panama, found cocaine, and determined the vessel was without nationality after Colombia could not confirm its registration. Canario-Vilomar was arrested on December 6, 2021, when a similar vessel was intercepted north of Colombia, and the Dominican Republic could not confirm its registration. Both defendants were charged with conspiracy to possess and distribute cocaine on a vessel subject to U.S. jurisdiction.
In the Southern District of Florida, Lemus pled guilty to both counts and was sentenced to 87 months in prison. In the Middle District of Florida, Canario-Vilomar pled guilty to conspiracy, and his motion to dismiss the indictment was denied. He was sentenced to 120 months in prison. Both defendants appealed, arguing that the MDLEA exceeded Congress's authority under the Felonies Clause of the Constitution and that their vessels were not stateless under international law. Canario-Vilomar also argued that his offense occurred in an Exclusive Economic Zone (EEZ), which he claimed was beyond Congress's regulatory authority.
The United States Court of Appeals for the Eleventh Circuit reviewed the case. The court held that Congress's authority under the Felonies Clause is not limited by international law, affirming that the MDLEA's definition of a "vessel without nationality" and the inclusion of the EEZ within the "high seas" were constitutional. The court also rejected Canario-Vilomar's due process argument, citing precedent that the MDLEA does not require a nexus to the United States for jurisdiction. Consequently, the Eleventh Circuit affirmed the convictions of both defendants.
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