Facts of the Case
Ahmad Abouammo, a former Twitter employee accused of passing dissidents' account data to a Saudi official, fabricated a consulting invoice at his Seattle home during an FBI interview and emailed it to the agents to support his story. He was indicted in the Northern District of California for falsifying a record with intent to obstruct a federal investigation under 18 U.S.C. § 1519, because the investigation was based in San Francisco, even though all of his conduct occurred in Seattle. The district court rejected his improper-venue challenge, and the Ninth Circuit affirmed.
Questions
Is venue proper in a district where no offense conduct took place, so long as the statute's intent element "contemplates" effects that could occur there?
Conclusions
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On June 11, 2026, the U.S. Supreme Court unanimously held in Abouammo v. United States that a prosecution for falsifying a record under 18 U.S.C. § 1519 must be brought in the district where the falsification occurred, not in the district where the targeted federal investigation was located.
Criminal Law & Procedure at the Supreme Court—A Recap of OT25
This term, several important questions of criminal law and procedure reached the Supreme Court, ranging...
Criminal Law & Procedure at the Supreme Court—A Recap of OT25
This term, several important questions of criminal law and procedure reached the Supreme Court, ranging...
