Abouammo v. United States

Summary

Justice Kagan delivered the unanimous opinion holding that a prosecution for falsifying a document under 18 U. S. C. §1519 must occur in the district where the falsification occurred, not a different district where the targeted investigation was located. Falsification is the offense’s only prohibited conduct; the intent to obstruct an investigation does not make contemplated effects additional conduct elements supporting venue elsewhere. The Court also rejected the Government’s characterization of §1519 as an inchoate offense whose venue could depend on conduct associated with another obstruction crime. Because Abouammo falsified the invoice in Seattle, his trial in the Northern District of California was improper. The Court reversed the Ninth Circuit’s judgment and remanded. There were no separate opinions.