The U.S. Court of Appeals for the Eleventh Circuit affirmed Franklin Dominguez's conviction under the Maritime Drug Law Enforcement Act for cocaine smuggling, rejecting multiple challenges to his prosecution in a per curiam opinion filed Tuesday.
Dominguez was convicted for smuggling cocaine aboard a go-fast vessel approximately 77 nautical miles southeast of Isla Beata, Dominican Republic, in the Caribbean Sea. The incident occurred on April 19, 2022, when a maritime patrol aircraft located the drifting vessel in a known drug-trafficking area.
According to a factual stipulation for trial, packages were observed drifting around the vessel, which displayed no indicia of nationality. The vessel was mostly submerged when discovered by authorities, indicating the typical pattern of drug smugglers who often abandon or scuttle their boats when detected by law enforcement.
On appeal, Dominguez raised three primary challenges to his conviction. First, he argued that the district court erred in denying his motion to dismiss the indictment as a sanction for the 24-day delay before his initial court appearance. Under federal rules, defendants must be brought before a magistrate judge without unnecessary delay, typically within 48 hours of arrest in most circumstances.
The timing issue represents a common challenge in maritime drug cases, where defendants are often arrested at sea and must be transported significant distances before reaching a U.S. port with federal court facilities. Maritime interdictions frequently involve complex logistics, including coordination between multiple agencies and the need to safely transport suspects across international waters.
Second, Dominguez challenged the constitutional basis for his prosecution, arguing that his offense did not occur on the "high Seas" as that phrase is used in the Felonies Clause in Article I of the U.S. Constitution. This constitutional provision grants Congress the power to define and punish felonies committed on the high seas, forming the foundation for federal jurisdiction over maritime crimes.
The jurisdictional challenge reflects ongoing legal debates about the geographical scope of federal maritime authority. The location of Dominguez's alleged offense, 77 nautical miles from Dominican Republic territory, placed it well within international waters where U.S. authorities routinely conduct counter-narcotics operations under various international agreements and treaties.
Third, Dominguez argued that the government failed to establish statutory jurisdiction under the MDLEA. The Maritime Drug Law Enforcement Act provides the primary federal framework for prosecuting drug trafficking on vessels, establishing specific jurisdictional requirements that prosecutors must prove to secure convictions.
The MDLEA allows the United States to prosecute drug trafficking offenses on vessels that are stateless, registered in countries that consent to U.S. enforcement action, or otherwise subject to U.S. jurisdiction under international law. The absence of nationality markings on Dominguez's vessel likely supported the government's jurisdictional argument under the stateless vessel provision.
The Eleventh Circuit's three-judge panel, consisting of Circuit Judges Jordan, Rosenbaum, and Kidd, reviewed all three challenges and found them without merit. The court issued its decision as a per curiam opinion, indicating unanimous agreement among the panel members on the outcome.
The case reflects the ongoing federal effort to combat drug trafficking in Caribbean waters, a major transit route for narcotics flowing from South America toward U.S. markets. Maritime interdiction operations represent a key component of federal counter-narcotics strategy, with multiple agencies including the Coast Guard, Navy, and DEA participating in coordinated enforcement efforts.
Go-fast boats, like the vessel involved in this case, are the preferred method for drug smugglers operating in Caribbean waters due to their speed and low profile. These vessels can carry substantial quantities of cocaine and are often abandoned when spotted by law enforcement aircraft or vessels.
The procedural challenges raised by Dominguez illustrate common defense strategies in maritime drug cases, where the remote locations of arrests and complex jurisdictional issues often provide grounds for challenging prosecutions. However, federal courts have generally upheld the government's authority to prosecute such cases under existing statutory frameworks.
The timing of the opinion, filed on February 4, 2026, suggests the case moved through the appeals process relatively quickly, reflecting the Eleventh Circuit's established procedures for handling maritime drug appeals on a non-argument calendar.
The affirmance means Dominguez's conviction and any associated sentence will stand, subject to any potential petition for further review. The decision reinforces federal authority to prosecute maritime drug trafficking cases and may influence similar challenges in pending cases throughout the circuit.
The case was originally prosecuted in the U.S. District Court for the Southern District of Florida, which handles a significant volume of maritime drug cases due to its jurisdiction over waters frequently used by drug traffickers. The district court's denial of Dominguez's dismissal motion was upheld entirely by the appeals court.