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11th Circuit Upholds Maritime Drug Trafficking Conviction

The U.S. Court of Appeals for the Eleventh Circuit affirmed the conviction of Ronald Mijail Arregoces Barros for conspiracy to possess five kilograms or more of cocaine aboard a vessel under U.S. jurisdiction. The January 7, 2026 ruling upholds the Southern District of Florida's original conviction in this high-seas drug trafficking case.

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Seal of the Eleventh Circuit Court of Appeals

Case Information

Case No.:
22-12552

Key Takeaways

  • Eleventh Circuit affirmed conviction for conspiracy to possess 5+ kilograms of cocaine on vessel under U.S. jurisdiction
  • Defendant challenged government authority under Maritime Drug Law Enforcement Act in foreign Exclusive Economic Zones
  • Court rejected constitutional arguments about Congress exceeding Felonies Clause authority regarding vessel nationality definitions
  • Case reinforces broad federal jurisdiction over maritime drug trafficking in international waters

The U.S. Court of Appeals for the Eleventh Circuit affirmed the conviction of Ronald Mijail Arregoces Barros for conspiracy to possess five kilograms or more of cocaine while aboard a vessel subject to U.S. jurisdiction. The court issued its ruling on January 7, 2026, rejecting multiple constitutional and jurisdictional challenges raised by the defendant.

Arregoces, also known as Ronald Mijail-Arregoces, was originally convicted in the U.S. District Court for the Southern District of Florida under case number 1:21-cr-20438-BB-1. The conviction stemmed from charges related to conspiracy to possess five kilograms or more of a mixture and substance containing a detectable amount of cocaine while on board a vessel subject to U.S. jurisdiction.

The case involves the application of the Maritime Drug Law Enforcement Act (MDLEA), federal legislation that extends U.S. jurisdiction over drug crimes committed on the high seas. The MDLEA allows the United States to prosecute drug trafficking offenses that occur aboard vessels without nationality or vessels subject to U.S. jurisdiction, even when those vessels operate in international waters.

On appeal, Arregoces raised three primary arguments challenging his conviction. First, he contended that the government's authority to prosecute crimes committed on the high seas under the MDLEA does not extend to conduct that occurs within a foreign nation's Exclusive Economic Zone (EEZ). An EEZ represents the maritime zone extending up to 200 nautical miles from a coastal state's baseline, where that nation has sovereign rights over natural resources but other countries retain certain navigation and overflight freedoms.

Second, Arregoces argued that Congress exceeded its constitutional authority under the Felonies Clause by defining "vessel without nationality" in the MDLEA to include vessels that are not stateless under international law. The Felonies Clause, found in Article I, Section 8 of the Constitution, grants Congress the power to define and punish felonies committed on the high seas. Arregoces contended that the statutory definition of vessels without nationality goes beyond what international law would recognize as stateless vessels.

Third, the defendant claimed that the government failed to prove that his vessel was actually subject to U.S. jurisdiction, a necessary element for conviction under the MDLEA. The statute requires that the government establish jurisdiction over the vessel where the alleged drug trafficking occurred.

The Eleventh Circuit panel, consisting of Circuit Judges Jordan, Lagoa, and Kidd, issued a per curiam opinion rejecting these arguments. The court's decision was designated "NOT FOR PUBLICATION" and was decided on the non-argument calendar, indicating that the panel determined oral arguments were not necessary for resolution of the appeal.

The case represents part of ongoing federal efforts to combat international drug trafficking through maritime interdiction operations. The MDLEA serves as a key tool for federal prosecutors in pursuing drug trafficking cases that occur in international waters, particularly in the Caribbean and Eastern Pacific regions where significant cocaine trafficking routes operate.

Maritime drug trafficking cases often present complex jurisdictional questions, as they involve the intersection of domestic criminal law, international law of the sea, and various bilateral agreements between nations. The United States has entered into numerous agreements with other countries to facilitate the prosecution of drug trafficking offenses discovered aboard vessels in international waters.

The affirmance of Arregoces' conviction reinforces the broad scope of federal authority under the MDLEA to prosecute drug trafficking offenses on the high seas. Federal courts have generally interpreted the statute expansively, allowing prosecution of defendants found aboard vessels that lack clear nationality or that can be connected to U.S. jurisdiction through various legal theories.

The ruling also demonstrates the continued judicial acceptance of congressional authority under the Felonies Clause to criminalize conduct occurring beyond U.S. territorial waters. Courts have consistently held that Congress possesses broad power to define and punish crimes committed on the high seas, even when those crimes involve foreign nationals or occur in areas where international law might provide alternative jurisdictional frameworks.

For maritime law practitioners, the decision reinforces established precedent regarding the extraterritorial application of U.S. criminal law in drug trafficking cases. The ruling suggests that challenges to MDLEA prosecutions based on EEZ location, vessel nationality definitions, or jurisdictional proof requirements face significant obstacles in federal appellate courts.

The case originated from what appears to be a routine maritime drug interdiction operation, the type of enforcement action that has become increasingly common as federal agencies work to disrupt international cocaine trafficking networks. Such operations typically involve coordination between the U.S. Coast Guard, Drug Enforcement Administration, and other federal agencies working in international waters.

Arregoces' conviction and the appellate court's affirmance represent another successful prosecution in the federal government's ongoing efforts to combat maritime drug trafficking through the MDLEA's expansive jurisdictional provisions.

Topics

maritime drug enforcementcocaine conspiracyvessel jurisdictioninternational watersconstitutional law

Original Source: courtlistener

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