Abouammov.United States
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.
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