Whether the MDLEA is unconstitutional due to lack of minimum-contacts or nexus 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 an Ecuadorian 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. Yet, Petitioner was charged in the Southern District of Florida for two violations of the Maritime Drug Law Enforcement Act (“MDLEA”). Petitioner pled guilty to one of them, conspiracy to possess with intent to distribute cocaine in violation of 46 U.S.C. §§70503(a)(1), 70506(b). This petition presents two critical questions about the constitutionality of the MDLEA: I. Whether the MDLEA is unconstitutional because the Government is not required to prove any “minimum contacts” or “nexus” between a defendant and the United States to establish jurisdiction over the cause. 2. Whether the MDLEA Violates Due Process Because It Does Not Comply With Miranda and Johnson In The Prosecution Of A Defendant Aboard a “Stateless Vessel” Under 46 U.S.C. §70502(d)(1)(B). i