USA v. Randar Munoz
Split Score
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Case Summary
Disposition
Affirmed
The Third Circuit affirmed Randar Vasquez Munoz’s conviction under the Maritime Drug Law Enforcement Act for conspiring to possess cocaine on a stateless vessel intercepted in international waters. Rejecting his arguments, the court held the MDLEA is a valid exercise of Congress’s Felonies Clause power and that the district court did not abuse its discretion in denying an evidentiary hearing on jurisdiction because the relevant facts were undisputed.
Circuit Split Identified
Legal Issue
Whether the MDLEA’s ‘vessel subject to the jurisdiction of the United States’ requirement is an element affecting subject-matter jurisdiction (thus going to the court’s power) or a non-jurisdictional question of law for the judge.
Circuit Positions
MDLEA jurisdictional prerequisites are non-element questions of law that do not limit Article III subject-matter jurisdiction.
MDLEA jurisdictional prerequisites are limitations on federal subject-matter jurisdiction and must be satisfied for the court to proceed.
Issue expressly noted but left undecided.
Conflict Summary
The First and Second Circuits treat the MDLEA’s jurisdictional language as a non-element preliminary issue that does not limit Article III subject-matter jurisdiction, whereas the Fifth, Eleventh, and D.C. Circuits hold that the same language is a prerequisite to federal subject-matter jurisdiction. In the present opinion, the Third Circuit expressly noted the split but declined to resolve the question.