Abouammo v. United States · ¶21

Our holding today is “discrete” and narrow, as our venue decisions usually are, because it is based on “the nature of the [specific] crime charged.” Travis v. United States, 364 U. S. 631, 635 (1961). Section 1519 prohibits only one act: that of falsifying a document. Because the Government need show nothing else, a §1519 offense is relatively easy to prove. But with that ease comes one cost: Because the Government need show nothing else, its venue options are confined. The trial for falsifying a document must take place where the defendant falsified the document. Here that was in Seattle—meaning in venue terms, the Western District of Washington. The trial should not have occurred in the Northern District of California because no “conduct constituting the offense” happened in that location. Rodriguez- Moreno, 526 U. S., at 279.

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