United States v. Yeiner Herrera-Barroz

CourtCourt of Appeals for the Eleventh Circuit
DecidedApril 28, 2025
Docket24-10149
StatusUnpublished

This text of United States v. Yeiner Herrera-Barroz (United States v. Yeiner Herrera-Barroz) 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. Yeiner Herrera-Barroz, (11th Cir. 2025).

Opinion

USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 1 of 9

[DO NOT PUBLISH] In the United States Court of Appeals For the Eleventh Circuit

____________________

No. 24-10149 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus YEINER HERRERA-BARROZ,

Defendant-Appellant.

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:23-cr-20162-KMW-2 ____________________ USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 2 of 9

2 Opinion of the Court 24-10149

No. 24-10175 Non-Argument Calendar ____________________

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus GUSTAVO RAFAEL BRITO-FERNANDEZ,

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:23-cr-20162-KMW-1 ____________________

No. 24-10217 Non-Argument Calendar ____________________ USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 3 of 9

24-10149 Opinion of the Court 3

UNITED STATES OF AMERICA, Plaintiff-Appellee, versus SAUL EMMANUEL BECERRA-ASTUDILLO, a.k.a. Saul Becerra,

Appeal from the United States District Court for the Southern District of Florida D.C. Docket No. 1:23-cr-20162-KMW-3 ____________________

Before NEWSOM, GRANT, and WILSON, Circuit Judges. PER CURIAM: Yeiner Herrera-Barroz, Gustavo Rafael Brito-Fernandez, and Saul Emmanuel Becerra-Astudillo (collectively, “Appellants”) ap- peal their convictions for conspiracy to possess with intent to dis- tribute cocaine on a vessel subject to United States jurisdiction. Ap- pellants challenge the district court’s jurisdiction over their cases, first arguing that the government lacked authority to prosecute them for a felony committed on the high seas under the Maritime Drug Law Enforcement Act (“MDLEA”) because their conduct USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 4 of 9

4 Opinion of the Court 24-10149

took place in Colombia’s exclusive economic zones (“EEZ”), and EEZs are excluded from the high seas under international law. Brito-Fernandez and Becerra-Astudillo also argue that the MDLEA unconstitutionally grants jurisdiction based on a definition of “ves- sel without nationality” that includes vessels that are not stateless under international law. Brito-Fernandez and Becerra-Astudillo further argue that their due process rights were violated because the MDLEA lacks a nexus requirement between the offense con- duct and the United States. After Appellants filed their initial briefs on appeal, the government moved for summary affirmance. I. 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 matter of law so that there can be no substantial question as to the outcome of the case, or where . . . the appeal is frivolous.” Groen- dyke Transp., Inc. v. Davis, 406 F.2d 1158, 1162 (5th Cir. 1969). 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). Likewise, we review “de novo a district court’s interpretation of a statute and whether a statute is constitutional.” Id. (quotation marks omitted). The MDLEA makes it a crime to “knowingly or intention- ally . . . possess with intent to manufacture or distribute, a USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 5 of 9

24-10149 Opinion of the Court 5

controlled substance” on board “a [covered] vessel subject to the jurisdiction 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 vessel.” 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). 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 (quotation marks omitted, alteration adopted); 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 constitu- tional challenges, we noted that we “repeatedly have upheld the USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 6 of 9

6 Opinion of the Court 24-10149

MDLEA as a valid exercise of Congress’s power to define and pun- ish . . . Felonies on the high Seas.” Id. at 820 (quotation marks omit- ted, second alteration in original). 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, “en- forcement 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, ar- guing, as relevant here, that the MDLEA exceeds Congress’s au- thority under the Felonies Clause of the Constitution, and that one appellant’s arrest did not occur on the high seas because he was arrested in Colombia’s EEZ. 128 F.4th 1374, 1376-78 (11th Cir. 2025). We relied on Alfonso 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 international law in crafting its definition of a state- less vessel or in defining the boundaries of the high seas.”). Again relying on Alfonso, we rejected an appellant’s argument “that Con- gress 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. “Under our prior-panel-precedent rule, a prior panel’s hold- ing is binding on all subsequent panels unless and until it is USCA11 Case: 24-10149 Document: 37-1 Date Filed: 04/28/2025 Page: 7 of 9

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overruled or undermined to the point of abrogation by the Su- preme Court or by this Court sitting en banc.” Id. at 1381 (quota- tion marks omitted, alteration adopted). “[W]e have categorically rejected an overlooked reason or argument exception to the prior- panel precedent rule.” Id. (quotation marks omitted).

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Related

United States v. Christopher Patrick Campbell
743 F.3d 802 (Eleventh Circuit, 2014)
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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Bluebook (online)
United States v. Yeiner Herrera-Barroz, Counsel Stack Legal Research, https://law.counselstack.com/opinion/united-states-v-yeiner-herrera-barroz-ca11-2025.