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Abouammov.United States

CourtSupreme Court of the United States
Docket No.25-5146
Decided2026-06-11
ReporterSlip Opinion, No. 25-5146
JudgesSupreme Court of the United States
Tags
Supreme CourtCriminal VenueObstruction of Justice18 U.S.C. § 1519Falsification of RecordsSixth AmendmentStatutory Interpretation
Case Summary

Abouammo was prosecuted under 18 U.S.C. § 1519 for falsifying records in contemplation of a federal investigation. The government tried the charge in the district where investigators were working, although the alleged falsification occurred elsewhere. The Supreme Court held that venue for a § 1519 offense lies where the defendant falsified, destroyed, or concealed the record, because those are the statute’s essential conduct elements. The location of the contemplated or existing federal investigation is a circumstance connecting the conduct to federal interests, not an additional place where the crime is committed. The conviction on that count was reversed and the case remanded.

Opinion

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Abouammo v. United States — The Atlanta Gleaner