United States v. Vazquez Valois

The Eleventh Circuit affirmed Defendants Vazquez, Valencia, and Portocarrero's convictions and sentences for trafficking cocaine in international waters, in violation of the Maritime Drug Law Enforcement Act. The court held that defendants' challenges to the district court's exercise of extraterritorial jurisdiction under the Act was foreclosed by binding precedent. Therefore, the district court properly exercised jurisdiction in this case.The court also held that the district court did not abuse its discretion when it denied Valencia's motion for mistrial; neither Portocarrero nor Vazquez have demonstrated that there was an actual conflict of interest under these circumstances; because Valencia and Portocarrero were not eligible for safety-valve relief in the first place, the court need not consider whether these defendants otherwise met the substantive requirements of safety-valve relief or defendants' constitutional claim based on the Fifth Amendment; the district court did not clearly err in denying Vazquez a minor role reduction under USSG 3B1.2(b); and any error in the guidelines calculation was harmless as both Valencia and Portocarrero received the statutory mandatory minimum sentence and the district court could not have sentenced them to less. View "United States v. Vazquez Valois" on Justia Law