US v. Beyle: Beyle and his codefendant, Abrar, were involved in a Somali pirate raid against a US sailboat, the Quest, which resulted in the death of four Americans on board and the intervention of the US Navy. Both were convicted of 26 counts related to the raid, including murder within the special maritime jurisdiction of the United States (which includes the "high seas") and discharge of firearms during a crime of violence and sentenced to multiple life sentences (some concurrent, some consecutive).
Beyle and Abrar both appealed their convictions, on different grounds, which the Fourth Circuit affirmed. As to Beyle, he argued that the district court lacked jurisdiction on the murder and firearm charges because they took place not on the "high seas" but in Somali territorial waters. The raid occurred in the middle of the Indian Ocean, but the Quest was turned by the pirates toward the Somali coast and was about 30 miles from the coast when the Navy intervened. While that was within the "exclusive economic zone" of Somalia, it was not within the more narrowly defined "territorial waters, which, by international treaty (to which Somalia is a party), extend only 12 miles from the coast.
As to Abrar, he argued that he was denied Fifth and Sixth Amendment rights with regard to his defense of duress - that he had been kidnapped and forced to take part in the raid. The court concluded that his inability to subpoena witnesses was not the fault of the United States, but simply due to the fact that the witnesses were foreign nationals residing in other countries. In addition, there was no evidence that the witnesses actually existed. Therefore, Abrar was not prevented from developing and presented a duress defense.