United States v. Yaneli Rafael Matos-Montas

CourtCourt of Appeals for the Eleventh Circuit
DecidedJuly 10, 2025
Docket23-10666
StatusUnpublished

This text of United States v. Yaneli Rafael Matos-Montas (United States v. Yaneli Rafael Matos-Montas) is published on Counsel Stack Legal Research, covering Court of Appeals for the Eleventh Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
United States v. Yaneli Rafael Matos-Montas, (11th Cir. 2025).

Opinion

USCA11 Case: 23-10666 Document: 38-1 Date Filed: 07/10/2025 Page: 1 of 6

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 23-10666 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus YANELI RAFAEL MATOS-MONTAS,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:22-cr-20283-RNS-1 ____________________ USCA11 Case: 23-10666 Document: 38-1 Date Filed: 07/10/2025 Page: 2 of 6

2 Opinion of the Court 23-10666

Before ROSENBAUM, ABUDU, and MARCUS, Circuit Judges. PER CURIAM: Yaneli Rafael Matos-Montas appeals his convictions for con- spiracy to possess with intent to distribute cocaine on a vessel sub- ject to United States jurisdiction and possession with intent to dis- tribute cocaine on a vessel subject to United States jurisdiction. On appeal, Matos-Montas challenges the district court’s jurisdiction over the case, arguing that: (1) the government lacked authority to prosecute him for a felony committed on the high seas under the Maritime Drug Law Enforcement Act (“MDLEA”) because his con- duct took place in Venezuela’s exclusive economic zone (“EEZ”) 31 nautical miles north of Los Monjes Island, Venezuela, and is ex- cluded from the “high seas” under international law; and (2) his due process rights were violated because the MDLEA lacks a nexus re- quirement between the offense conduct and the United States, and neither his conviction nor his specific offense bore any connection to the United States. In response to Matos-Montas’s initial brief on appeal, the government moved for summary affirmance. After careful review, we grant the motion for summary affirmance. Summary disposition is appropriate either where time is of the essence, such as “situations where important public policy is- sues are involved or those where rights delayed are rights denied,” or where “the position of one of the parties is clearly right as a mat- ter of law so that there can be no substantial question as to the USCA11 Case: 23-10666 Document: 38-1 Date Filed: 07/10/2025 Page: 3 of 6

23-10666 Opinion of the Court 3

outcome of the case, or where . . . the appeal is frivolous.” Groen- dyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). 1 When a motion to dismiss the indictment is based on subject matter jurisdictional grounds, we review the district court’s denial de novo. United States v. Alfonso, 104 F.4th 815, 820 (11th Cir. 2024). We also review “de novo a district court’s interpretation of a statute and whether a statute is constitutional.” Id. The MDLEA makes it a crime to “knowingly or intention- ally . . . possess with intent to manufacture or distribute, a con- trolled substance” on board “a [covered] vessel subject to the juris- diction of the United States,” and to conspire to do the same. 46 U.S.C. §§ 70503(a)(1), (e)(1), 70506(b). The statute defines a “vessel subject to the jurisdiction of the United States” as including “a vessel without nationality.” Id. § 70502(c)(1)(A). A “vessel with- out nationality” is defined to include “a vessel aboard which the master or individual in charge fails, on request of an officer of the United States authorized to enforce applicable provisions of United States law, to make a claim of nationality or registry for that ves- sel.” Id. § 70502(d)(1)(B). The MDLEA “applies even though the act is committed outside the territorial jurisdiction of the United States.” Id. § 70503(b).

1 In Bonner v. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en banc), we

adopted as binding precedent all Fifth Circuit decisions issued before October 1, 1981. USCA11 Case: 23-10666 Document: 38-1 Date Filed: 07/10/2025 Page: 4 of 6

4 Opinion of the Court 23-10666

Under Article I, Section 8, Clause 10 of the Constitution, Congress has “three distinct grants of power: (1) the power to de- fine and punish piracies, (the Piracies Clause); (2) the power to de- fine and punish felonies committed on the high Seas, (the Felonies Clause); and (3) the power to define and punish offenses against the law of nations (the Offences Clause).” Alfonso, 104 F.4th at 820 (ci- tation modified); U.S. Const. art. I, § 8, cl. 10. In Alfonso, the defendants, who had been seized by the United States Coast Guard on a vessel in the Dominican Republic’s EEZ, appealed their convictions under the MDLEA and challenged the constitutionality of the MDLEA as applied to them under the Felonies Clause. 104 F.4th at 818–19. In response to their consti- tutional challenges, we noted that we “repeatedly have upheld the MDLEA as a valid exercise of Congress’s power to define and pun- ish . . . Felonies on the high Seas.” Id. at 820 (citation modified). We also held that “international law does not limit the Felonies Clause.” Id. at 826. We further held that a nation’s EEZ is “part of the ‘high seas’ for purposes of the Felonies Clause in Article I of the Constitution,” and thus, “enforcement of the MDLEA in EEZs is proper.” Id. at 823, 827. We affirmed this holding in United States v. Canario-Vilomar, in which two appellants -- one seized in a vessel 37 nautical miles north of Panama, the other seized in a vessel 145 nautical miles north of Colombia -- challenged the district court’s jurisdiction. 128 F.4th 1374, 1376–78 (11th Cir. 2025). Relevant here, the appel- lants argued in Canario-Vilomar that the MDLEA exceeds USCA11 Case: 23-10666 Document: 38-1 Date Filed: 07/10/2025 Page: 5 of 6

23-10666 Opinion of the Court 5

Congress’s authority under the Felonies Clause of the Constitu- tion, and that one appellant’s arrest did not occur on the high seas because he was arrested in Colombia’s EEZ. Id. We relied on Al- fonso and similarly concluded that Congress was not constrained by international law in crafting the MDLEA. Id. at 1381 (“[W]e reject [appellants’] contention that Congress was constrained by interna- tional law in crafting its definition of a stateless vessel or in defining the boundaries of the high seas.”). Again relying on Alfonso, we also rejected an appellant’s argument “that Congress could not reach him merely because he chose to traffic drugs in Colombia’s EEZ rather than farther out into the open ocean.” Id. at 1382. Finally, Canario-Vilomar addressed the claim “that the MDLEA violates principles of due process because it allows the United States to assert jurisdiction over foreign nationals for con- duct that bears no nexus with the United States,” although the ap- pellant acknowledged that we had rejected similar arguments. Id. We agreed with the appellant that the argument was “plainly fore- closed by our binding precedent.” Id. at 1382–83 (citing United States v. Campbell, 743 F.3d 802, 810 (11th Cir. 2014)). In so holding, we emphasized that “we have explained repeatedly” that “the con- duct proscribed by the MDLEA need not have a nexus to the United States because universal and protective principles support its extraterritorial reach.” Id. at 1383 (citation modified).

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Related

Larry Bonner v. City of Prichard, Alabama
661 F.2d 1206 (Eleventh Circuit, 1981)
United States v. Christopher Patrick Campbell
743 F.3d 802 (Eleventh Circuit, 2014)
United States v. Trinity Rolando Cabezas-Montano
949 F.3d 567 (Eleventh Circuit, 2020)
United States v. Jhonathan Alfonso
104 F.4th 815 (Eleventh Circuit, 2024)
United States v. Carlos Daniel Canario-Vilomar
128 F.4th 1374 (Eleventh Circuit, 2025)

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United States v. Yaneli Rafael Matos-Montas, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-yaneli-rafael-matos-montas-ca11-2025.