Beyle was a Somali pirate. The District Court convicted Beyle on 26 criminal counts arising from the armed abduction and murder of four US citizens off the coast of Somalia. The site of the murder was 30-40 nm from the Somali coast.

Beyle appealed. He argued that the District Court lacked jurisdiction over the murder and firearms charges against him because the US citizens were not killed on the high seas, but within Somalia's exclusive economic zone (EEZ). Beyle relied on the United Nations Convention on the Law of the Sea 1982 (UNCLOS) and argued that UNCLOS treated the EEZ as a distinct quasi-territorial entity and that the high seas did not begin until 200 nautical miles from land. In addition, Beyle argued that had Somalia passed national legislation in 1972 that extended its territorial sea to 200 nautical miles.

Held: Appeal dismissed.

It is well-settled that the 'high seas' encompass all those waters beyond the boundary of the various territorial waters. UNCLOS recognises an EEZ beyond a nation's territorial sea but within 200 nautical miles of the coastal baseline. While it is true that the part of UNCLOS that is titled 'High Seas' concerns the waters extending beyond the borders of the EEZ, almost all of the treaty's high-seas provisions apply with equal force inside the EEZ as they do outside it. The EEZ bordering a particular nation's territorial sea is merely a part of the high seas where that nation has special economic rights and jurisdiction. UNCLOS grants coastal nations certain rights to natural resources within the EEZ, as well as jurisdiction over marine scientific research and protection and preservation of the marine environment. 

In addition, a nation's territorial sea is generally limited to an area within 12 nautical miles of the nation's coast. Somalia ratified UNCLOS in 1989, making a clear international commitment to a territorial sea of no more than 12 nautical miles. Further, Somalia never submitted a declaration that indicated any non-adherence to any provision of UNCLOS. Moreover, UNCLOS prohibits signatories from selectively opting out from its provisions in any event. Finally, the United States has explicitly stated that it does not recognise any claim by Somalia to a 200-nautical-mile territorial sea. Therefore, Beyle was on the high seas when the murder occurred and his appeal was dismissed.