The U.S. Court of Appeals for the Eleventh Circuit affirmed the convictions of two defendants charged under the Maritime Drug Law Enforcement Act for conspiracy to distribute controlled substances on a vessel subject to U.S. jurisdiction. In a per curiam opinion filed Jan. 13, 2026, the court rejected challenges raised by Roberto Peralta Ibarra and Alberto Peguero, both of whom appealed their convictions from the U.S. District Court for the Southern District of Florida.
The consolidated appeals, designated as case numbers 22-13655 and 22-13743, involved charges stemming from drug trafficking activities on vessels under federal maritime jurisdiction. Both defendants were convicted under the Maritime Drug Law Enforcement Act, a federal statute that extends U.S. criminal jurisdiction to drug trafficking offenses committed on vessels subject to American legal authority, even when those vessels operate in international waters.
Ibarra challenged only his conviction, while Peguero appealed both his conviction and the sentence imposed by the district court. The cases originated in the Southern District of Florida under criminal docket number 1:21-cr-20581-DPG, indicating the prosecution began in 2021 before District Judge Darrin Gayles.
The Eleventh Circuit panel, consisting of Circuit Judges Robin Rosenbaum, Charles Grant, and Susan Black, issued an unpublished opinion addressing what the court described as "several issues" raised by the appellants. The court's per curiam format indicates the judges reached a unanimous decision without identifying a single author of the opinion.
The Maritime Drug Law Enforcement Act serves as a key federal tool for prosecuting drug trafficking cases that occur on vessels in international waters or areas beyond traditional territorial jurisdiction. The statute allows federal prosecutors to charge individuals with conspiracy to distribute controlled substances when their activities involve vessels subject to U.S. jurisdiction, regardless of the vessel's location when the alleged crimes occurred.
Federal maritime drug prosecutions typically involve complex jurisdictional questions, as prosecutors must establish that the vessel falls under U.S. legal authority. This can include vessels flying American flags, vessels owned by U.S. citizens, or vessels that lack proper documentation from any nation, making them stateless under international law.
The appeals court's decision to place both cases on the "Non-Argument Calendar" suggests the panel determined that oral arguments were unnecessary to resolve the legal issues presented. Courts typically reserve this designation for cases where the legal questions are straightforward or where existing precedent clearly governs the disputed issues.
Both defendants' cases were processed through the federal court system in Miami, which handles a significant volume of maritime drug prosecutions due to its proximity to major drug trafficking routes through the Caribbean and along Florida's extensive coastline. The Southern District of Florida has developed substantial expertise in prosecuting cases under the Maritime Drug Law Enforcement Act.
The timing of the appeals reflects the typical progression of federal criminal cases. With the original charges filed in 2021 and appeals decided in early 2026, the cases followed a standard timeline that included trial proceedings, sentencing, and the appellate process. The consolidation of the two appeals likely reflected similar legal issues and factual circumstances underlying both prosecutions.
The unpublished status of the opinion indicates that while the decision resolves the immediate appeals, it will not serve as binding precedent for future cases in the Eleventh Circuit. Federal appeals courts typically reserve published opinions for cases that establish new legal principles or clarify existing law, while routine affirmances of trial court decisions often result in unpublished dispositions.
Peguero's challenge to his sentence suggests he argued that the district court imposed an inappropriate penalty under federal sentencing guidelines. Federal drug conspiracy sentences must comply with statutory minimums and maximums while considering factors such as the defendant's role in the conspiracy, criminal history, and the quantity of drugs involved.
The Eleventh Circuit's jurisdiction encompasses Alabama, Florida, and Georgia, making it a frequent venue for maritime drug prosecutions given the region's extensive coastline and proximity to international drug trafficking routes. The court has developed considerable precedent interpreting the Maritime Drug Law Enforcement Act and related federal statutes.
The defendants may still pursue further appeals by petitioning the Supreme Court for certiorari, though the high court accepts only a small percentage of such requests. Given the routine nature of the appellate issues and the unpublished disposition, further review appears unlikely unless the case presents novel legal questions of national importance.
This decision reinforces federal prosecutors' authority to pursue drug trafficking cases under maritime jurisdiction, even when the alleged crimes occur in international waters. The Maritime Drug Law Enforcement Act continues to serve as a vital tool for federal law enforcement agencies working to disrupt drug trafficking organizations that operate beyond traditional territorial boundaries.