Abouammo v. United States · ¶20

The fundamental problem with that theory is that §1519 is an independent crime, not an inchoate offense. The Government, in arguing its case, points to Black’s Law Dictionary’s definition of the term. See Brief for United States 28. But there we find the following: “The three inchoate offenses are attempt, conspiracy, and solicitation”—as in, say, a conspiracy to commit murder, an attempt to commit murder, and the solicitation of murder. Black’s Law Dictionary 1297 (12th ed. 2024). The Government does not claim that §1519 is one of those three. And even if inchoate offenses are not a closed set, they are necessarily, as Black’s also says, “[a] step toward the commission of another crime.” Ibid. But a §1519 offense need not be. Section 1519 has no specific object crime, in the way inchoate offenses do: The Government notably does not identify any obstructionof-justice statute whose…

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