United States v. Campbell

Christopher Campbell and two other men (defendants) were on a boat that had no obvious ties to a particular country. While the boat was in international waters, the United States Coast Guard pursued the boat, and the men dumped several bales of marijuana into the ocean during the pursuit. After being caught by the Coast Guard, Campbell claimed that the boat was registered in Haiti. However, the Haitian government would neither confirm nor deny the registration claim. The men were arrested and charged in United States federal court with violating the Maritime Drug Law Enforcement Act (MDLEA) by (1) possessing a controlled substance with the intent to distribute it and (2) conspiring to distribute a controlled substance. The MDLEA allowed the United States to prosecute anyone who manufactured, possessed, or distributed a controlled substance in a vessel that (1) was stateless, (2) was in United States waters, or (3) was registered to or in the waters of a country that agreed to allow the enforcement of United States law. A vessel was stateless if the claimed country of origin would not confirm the vessel’s registration. The MDLEA did not require any nexus or connection between the alleged criminal conduct and the United States. Campbell was convicted of both charges. On appeal, Campbell argued that (1) Congress lacked authority to pass a law that criminalized conduct with no connection to the United States and (2) the MDLEA violated his right to due process because he had no notice that he could be held criminally liable for conduct with no connection to the United States.