Case Explained: Non-Argument Calendar UNITED STATES OF AMERICA v. WASHINGTON FRANCISCO MERO-MERO JUAN CARLOS MARIN-MERO ANTHONY BRYAN MERO-MERO Appeals from the United States District Court for the Southern District of Florida

Court: United States Court of Appeals for the Eleventh Circuit Filed: 2026-07-29 Docket: 1:23-cr-20477-JB-1 The eleventh-circuit affirmed the convictions and sentences of three defendants for drug trafficking offenses under the Maritime Drug Law Enforcement Act (MDLEA). The court held that the MDLEA is constitutional as applied to conduct within another nation’s Exclusive Economic Zone, relying on binding precedent in *United States v. Alfonso*, which establishes that the EEZ constitutes part of the “high seas” under the Felonies Clause and is not limited by customary international law. Additionally, the court found the statute’s definition of a “vessel without nationality” constitutional, as Congress has broad authority to define such vessels regardless of international law standards. The court further rejected the defendants’ argument that the government violated Federal Rule of Criminal Procedure 5(a) by delaying their presentment before a magistrate judge for twenty days after capture, finding the delay was necessary due to the distance from the nearest port and the Coast Guard’s ongoing interdiction mission, with no evidence of mistreatment or improper interrogation. Finally, the court affirmed the denial of a minor-role sentencing reduction under U.S.S.G. § 3B1.2(b) for one defendant, concluding that the district court did not clearly err in determining that the defendant played a significant role in the specific offense conduct of transporting the drugs rather than a minor role in a broader conspiracy. The defendants’ convictions and concurrent 78-month sentences remain in effect. Do It For The Case Law is a news reporting service. Nothing in this episode constitutes legal advice.