Whether the MDLEA is unconstitutional due to lack of minimum-contacts requirement

QUESTIONS PRESENTED Petitioner was onboard a boat in international waters in the Eastern Pacific Ocean when the United States Coast Guard (“USCG”) detained him for cocaine trafficking. Petitioner is a Colombian citizen, the boat was not registered in the United States, there was no evidence the cocaine was destined for the United States, and there was no nexus between the petitioner and the United States. Petitioner was charged in the Southern District of Florida for two violations of the Maritime Drug Law Enforcement Act (“MDLEA”), 46 U.S.C. §§70503(a), 70506(b). A jury found him guilty of those two violations. This case presents three critical questions about the constitutionality of the MDLEA: 1. Whether the MDLEA is unconstitutional because the Government is not required to prove any “minimum contacts” between a defendant and the United States to establish jurisdiction over the cause. 2. Whether the MDLEA pretrial procedures to establish jurisdiction over a “stateless vessel” violate the Confrontation Clause of the Sixth Amendment. 3. Whether §70502(d)(1)(C) of the MDLEA is void for vagueness because it does not contain a time limit for a foreign nation to confirm whether a vessel is of its nationality before the United States can declare it “stateless” and subject its occupants to the jurisdiction of United States courts. i