First, the Court rejected the defendant's argument that the MDLEA's failure to permit safety-valve relief violated equal protection and due process. Applying a rational basis test, the Court concluded that there were legitimate reasons for Congress to craft stricter sentences for MDLEA offenses than domestic drug offenses given pressing concerns about foreign relations, global treaty obligations, and deterrence.
Second, the Court rejected as foreclosed by precedent the argument that the MDELA violates due process by subjecting foreign nationals to U.S. prosecution absent a nexus to the U.S.
Third, the Court concluded that the defendant could not challenge the constitutionality of his detention on appeal. Although he argued that a 19-delay before presentment to a magistrate judge was unreasonable and violated due process, the Court found that his guilty plea precluded him from raising that argument on appeal, citing the Supreme Court's recent decision in Class. The defendant could not circumvent that bar by characterizing his complaint as a constitutional challenge to the MDLEA. Thus, the Court could not reach the merits of his detention.
Judge Martin concurred in the judgment. She agreed with the first two holdings, but disagreed with the holding that, by pleading guilty, the defendant waived his argument that a 19-day detention between arrest and first appearance violated due process. She did not read Class or circuit precedent as supporting that result. Nonetheless, she concluded that the delay in this case was reasonable.
