Abouammo v. United States
No. 25-5146 · Decided June 11, 2026 · reversed and remanded
Whether a defendant charged with violating 18 U.S.C. §1519—which makes it a crime to knowingly falsify a document with the intent to obstruct a federal investigation—must be tried in the district where the falsification occurred. A defendant charged with violating 18 U.S.C. §1519 must be tried in the district where the falsification occurred, not in the district where the investigation was located.
CERTIORARI TO THE UNITED STATES COURT OF APPEALS FOR · Argued March 30, 2026
Parties — Petitioner: ABOUAMMO · Respondent: UNITED STATES
Vote & lineup9–0 (unanimous) on the judgment. Kagan delivered the opinion for a unanimous Court (9).
Who prevailed — The petitioner prevailed on the issue of improper venue, resulting in the reversal of the Ninth Circuit's judgment.
The question

Whether a defendant charged with violating 18 U.S.C. §1519—which makes it a crime to knowingly falsify a document with the intent to obstruct a federal investigation—must be tried in the district where the falsification occurred. Alternatively, the Court considers whether the defendant may be tried in the district where the federal investigation was located. This question concerns the proper venue for trying an alleged violation of the statute.

Petitioner's argument
  • Venue is only proper in the district where the alleged falsification of the invoice occurred.
  • In this case, that location was Seattle, within the Western District of Washington.
  • The Northern District of California is an improper venue because the prohibited conduct did not take place there.
Respondent's argument
  • Venue is proper in the district where the FBI investigation was located because the "contemplated effects" of the falsification are part of the offense's "essential conduct."
  • The transmission of the false invoice to an agent in San Francisco makes the Northern District of California a proper venue.
  • Section 1519 is an "inchoate offense" with an integral relationship to other obstruction-of-justice crimes, allowing venue to be based on conduct that would be critical to proving those ultimate crimes.
The decision
  • The Court held that a defendant charged under 18 U.S.C. §1519 must be tried in the district where the falsification occurred and cannot be tried where the investigation was located.
  • The Court relied on Article III, §2, cl. 3 and the Sixth Amendment, which guarantee that criminal trials be held in the state and district where the crime was committed.
  • To determine venue, the Court applied the test from *United States v. Rodriguez-Moreno*, which requires identifying the "essential conduct elements"—the acts a defendant must perform to violate the statute—and ascertaining where those acts occurred.
  • The Court reasoned that under 18 U.S.C. §1519, the only prohibited act is the falsification of a document; once this act is committed with the requisite intent, the crime is complete.
  • The Court rejected the idea that the statute's mens rea (the "intent to obstruct") affects venue, noting that a falsification with intent occurs in the same place as one without intent.
  • The Court distinguished §1519 from laws barring actual obstruction (such as 18 U.S.C. §1512(c)(2)), noting that §1519 does not require the falsification to actually impact an investigation.
  • Citing *United States v. Johnson*, the Court noted that when a crime is complete upon a specific act, venue is fixed at the location of that act, regardless of where the document is received or the intended effect.
  • The Court rejected the Government's "inchoate offense" theory, citing *Black's Law Dictionary* to conclude that §1519 is a standalone crime rather than a "step toward the commission of another crime."
Read the full opinion on supremecourt.gov (PDF) →