Abouammo v. United States

608 U. S. ___ (2026) · 6/11/26

A defendant charged with knowingly falsifying a document with the intent to obstruct a federal investigation in violation of 18 U. S. C. §1519 must be tried in the district where the falsification occurred; the defendant cannot be tried in a different district where the investigation was located because no “conduct constituting the offense” happened there.

This case presents 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, or whether he may alternatively be tried in the district where the federal investigation was located. While employed by Twitter at its San Francisco office, petitioner Ahmad Abouammo provided confidential information to a high-level Saudi official about Saudi dissidents posting on the company’s platform. In exchange, the official…

Held: A defendant charged with violating §1519 must be tried in the dis- trict where the falsification occurred; he cannot be tried in a different district where the investigation was located because no “conduct con- stituting the offense” happened there. The Constitution twice safeguards a defendant’s venue right: Article III instructs that “Trial of all Crimes” shall “be held in the State where the Crimes shall have been committed,” §2, cl. 3, and the Sixth Amend- ment entitles criminal defendants to a jury “of the State and district wherein the crime shall have been committed.” To…