In U.S. v. de la Cruz, No. 04-15193 (March 27, 2006), the Court held that jurisdiction under 46 U.S.C. App. § 1903 was established over a vessel seized with 1800 kilos of cocaine in international waters. The vessel in question flew no flag, carried no registration paperwork, and bore no markings indicating its nationality. The vessel’s captain concealed himself. Hence, the vessel qualified as one "without nationality" under section 1903.
The Court also found that the defendant failed, under U.S. v. Rodriguez de Varon, 175 F.3d 930 (11th Cir 1999) to establish clear error in the denial of a minor role sentence reduction, in view of the fact that he was paid for his efforts, and participated in prior maritime drug smuggling activities.