U.S. Court of Appeals for the Ninth Circuit
United States v. Gessen
September 8, 2026
Summary
The Ninth Circuit affirmed Allen Gessen’s murder‑for‑hire conviction, rejecting his proposed jury instruction on a quid pro quo requirement, finding the evidence sufficient to prove all elements of 18 U.S.C. § 1958, and holding that venue was proper in the Northern District of California because the offense is a continuing crime.